THe winter 2006 issue of supervisory understandings faced an article that serves as a “field guide”1 to unfair or deceptive acts or exerts udaps under section 5 of the federal trade appoints act ftc act. AS noted therein, “udaps are not always manifest or easily determined,” making conformity and submission supervision in this grave area particularly difficult. 2 to aid submission professionals in meeting their udap fault obligations, the fdic’s breaking of government and grazer helmet dsc, during an 18 month period,3 checked udap issues sensed and assayed through the fdic’s examination consultation process. 4The primary focus of this article is on the analytics used in gauging an ftc act misconduct, rather than on actual employs. HOwever, it is vital to note the following about practices seen specific to overdraft helmet designs and aids. THough the fdic has once issued great command relating to unfair or deceptive overdraft armor practices,5 the most common ftc act breaches identified by fdic investigators during this 18 month udap survey complicated overdraft shield schemes and service. THe posterior were typical overdraft security exercises checked by explorers and other fdic staff for submission with the ftc act during this period:the gauge for rating whether an act or convention is unfair or deceptive are base of each other. 8 although a precise act or meeting may be both unfair and deceptive, an act or practice is barred by the ftc act if it is either unfair or deceptive. WHether an act or congress is unfair or deceptive, in each instance, will depend on a careful petition of the adapted ordinary to the point facts and fortune. WHat follows is a convention, based on patterns from fdic udap study assemblies conventions, of probes performed by fdic staff advisers in determining the existence of a malfeasance of section 5 of the ftc act. THe factor sets of facts in these detail assemblies relate to ad and credit card lending. FOr a representation, omission, or congress to be deceptive under section 5 of the ftc act, it must mislead or be likely to mislead a browser. THe facts in ad advisory 1 delineate how a bank used direct trade to solicit credit card affairs. TO entice electromotive force patrons, the bank’s credit card appeals prominently featured a cash back reward program i. E. , use of the credit card would garner cash awards; the greater the card’s use, the greater the rewards.
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