Is this incentive program a UDAAP violation?

“bonuses or employment status to unrealistic sales goals or to the terms of transactions may intentionally or unintentionally encourage illegal practices” – CFPB Bulletin dated NOV 28, 2016

GUEST EDITORIAL

Well let me see if I fully understand this new Wells Fargo Incentive Program. To quote from an article published by ARA President, Vaughn Clemmons, “This past week, Scott Darling shared news about an initiative that Wells Fargo presented to all of their nationwide forwarding vendors last week.” This was the very first time we were introduced to the program.

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Is this incentive program a UDAAP violation? – ARA – CFPB