As federal regulators continue to roll back rulemaking and enforcement efforts, private litigation may play an increasingly important role in UDAP enforcement. According to one recent survey, private UDAP lawsuits against financial institutions reached their highest level in 2025. This presentation will provide an overview of recent California Unfair Competition Law (UCL) litigation against banks, credit unions, and other financial
services providers, with a particular focus on the wide-ranging conduct and circumstances alleged to constitute unfair or deceptive acts or practices. By examining the factual patterns underlying these cases, the presentation is intended to help financial institutions identify areas of heightened litigation risk and evaluate opportunities to mitigate UDAP risk within their own products, practices, and operations. Handout to be posted on Thursday, September 17th!
