The Consumer Financial Protection Bureau initiated a pair of potentially significant enforcement actions in recent weeks, but the agency has yet to really reveal any noteworthy part of its strategic playbook under its “unfair, deceptive and abusive acts and practices” authority as per the Dodd-Frank Act. One of the take-aways from these cases is that “the CFPB did not rely on its UDAAP authority to provide any look into what they may consider abusive,” said Donald Lampe, partner and head of the financial services regulatory...