Introduction
One of the many innovations in the Dodd-Frank Act was the inclusion of a prohibition on ''abusive'' conduct. This new standard provided the Consumer Financial Protection Bureau (the ''Bureau'' or ''CFPB'') with a new enforcement tool, but little guidance on what conduct it proscribed. This lack of clarity has gotten worse — not better — over the past four years.
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Originally published in Bloomberg BNA's Banking Report on January 27, 2015.
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