Reg. AA and UDAAP: Changing of the Guard
While the Fed proposed to repeal Reg. AA, the federal banking agencies have issued guidance on unfair or deceptive credit practices. The agencies are quick to point out that the repeal of Reg. AA should not be seen as a signal that deceptive credit practices it prohibited are now permissible. This move is more of a changing of the guard. [8/27/14]