When the concept of unfair, deceptive, or abusive acts or practices was first introduced, many assumed it would target companies that adopted practices that were either intentionally or willfully misleading.
Through various enforcement actions, it is clear that the standard for UDAAP is more akin to mere negligence. The latest enforcement under UDAAP — against JPMorgan Chase & Co. — demonstrates that UDAAP claims can be built on activities that are likely more the result of systemic failures rather than any intention to mislead consumers.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide.
Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.
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