In our view, the proposed advertising slogan would raise significant UDAAP risks. It may not technically violate the Regulation DD requirement prohibiting advertisements that “refer to or describe an account as ‘free’ or ‘no cost’” if certain fees, such as a monthly maintenance fee, are imposed on the account. 12 CFR 1030.8. However, the CFPB has the power to deem any practice “unfair, deceptive, or abusive,” even if the practice does not violate any law or regulation. 12 USC 5531. Because an advertisement stating that a product is “better than free” could easily be misinterpreted or viewed as confusing customers, we strongly recommend considering the UDAAP risks raised by the advertisement.