This article is the second in a series of six articles concerning UDAAP. Read part one here.

According to the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Consumer Financial Protection Bureau (CFPB) can declare “unfair,” and thus unlawful, any act or practice in connection with a transaction for a consumer financial product or service, or the offering of a consumer financial product or service, so long as the CFPB has a reasonable basis to conclude that:

a) the act or practice causes or is likely to cause substantial injury to consumers that they can't reasonably avoid