Earlier this week, Benjamin Lawsky, the Superintendent of the New York Department of Financial Services (DFS), became the first state regulator to use his authority under Dodd-Frank Section 1042 to bring a civil action for a violation of the Dodd-Frank prohibition of unfair, deceptive or abusive acts or practices (UDAAP).  Similar to most other states’ laws prohibiting unfair or deceptive acts or practices (UDAP), New York’s General Business Law only allows UDAP actions to be filed by the state’s attorney general.  … Continue Reading