Federal Deception Law: 4.4.4.5 Are the Creditor’s Actions Within the UDAP Statute’s Scope?
When the FTC Holder Notice is included in a contract or promissory note, the consumer can raise a seller-related UDAP claim against the creditor even if the creditor is not within the scope of the UDAP statute.291 All that is required is that both the seller and the challenged practice are within the scope of the UDAP statute.