Here, by Kate Berry (behind a paywall). The most potent weapon is, of course, the Bureau's UDAAP powers. Excerpt:
[The Bureau's] vision statement unveiled as part of the new strategic plan dropped any reference to so-called UDAAP claims, suggesting that the agency will not use the Dodd-Frank authority as the same kind of blunt enforcement tool that resulted in scores of fines under Cordray. * * *
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The CFPB's reliance on UDAAP in recent years is important because more than 90% of the $12 billion in consumer relief awarded by the CFPB came in cases in which the bureau uncovered evidence of deception, according to data through 2015.
