NMLS 2739485
Unfair, Deceptive, or Abusive Acts or Practices
Effective Date: June 1, 2026
1. Purpose
Clara Risus LLC is committed to treating every customer fairly, honestly, and respectfully. The purpose of this policy is to prevent unfair, deceptive, or abusive acts or practices (UDAAP/UDAP) in connection with our products, services, communications, and customer relationships.
2. Equal Treatment
All customers are equal.
Clara Risus LLC will provide customers with fair and consistent treatment and will not intentionally treat one customer less favorably than another based on prohibited discriminatory factors or other unlawful considerations.
Customers will be evaluated based on legitimate business and credit-related criteria applicable to their individual circumstances.
3. Fair and Honest Communications
Clara Risus LLC will strive to ensure that information provided to customers is:
- Accurate and truthful.
- Clear and understandable.
- Not misleading or deceptive.
- Consistent with the actual terms and conditions of the customer’s agreement.
- Provided in a manner that allows customers to understand important costs, obligations, and conditions.
- Material terms and conditions should not be hidden or presented in a manner designed to mislead a reasonable customer.
4. No Unfair or Abusive Practices
Clara Risus LLC will not intentionally engage in practices that cause or are likely to cause substantial consumer injury that cannot reasonably be avoided, when the injury is not outweighed by applicable benefits to consumers or competition.
Clara Risus LLC will also avoid practices that materially interfere with a customer’s ability to understand the terms or conditions of a financial product or service or that take unreasonable advantage of a customer’s lack of understanding, inability to protect their interests, or reasonable reliance on the company.
5. Customer Complaints
Customers may raise questions or complaints regarding their account, payments, credit decisions, disclosures, or treatment by Clara Risus LLC.
Complaints will be reviewed in a fair and timely manner. Clara Risus LLC will not intentionally retaliate against a customer for raising a legitimate concern or exercising a legal right.
6. Employee and Management Responsibility
Employees, representatives, and management of Clara Risus LLC are expected to:
- Treat customers fairly and respectfully.
- Provide accurate information.
- Follow approved policies and procedures.
- Avoid misleading statements or omissions.
- Clearly communicate material terms and conditions.
- Escalate potential compliance concerns or customer complaints to management.
7. Compliance Commitment
Clara Risus LLC will periodically review its policies, procedures, communications, and customer interactions to identify and address potential UDAAP/UDAP risks.
Our commitment is simple:
Every customer deserves fair, honest, respectful, and equal treatment. Clara Risus LLC looks at the customer as a person—not simply as a number.
Clara Risus LLC
NMLS 2739485