The federal prudential regulators have increased their focus on bank-fintech arrangements, including the potential consumer confusion created in these arrangements. Regulators have often used their UDAAP/UDAP authority to address consumer confusion in the marketplace. This panel discusses recent federal and state UDAAP/UDAP developments in bank partnership relationships. In this discussion, the panel reviews the federal prudential regulators’ use of their UDAP authority and concerns about multi-party liability related to UDAPs with respect to end users.
