UDAAP: Unfair, Deceptive Acts and Practices

Starting now, banks have to look at compliance through the lens of consumer satisfaction. Model forms and correct disclosures are no longer all that is needed.  UDAAP is a game changer for financial institutions.

UDAAP compliance starts with a Risk Assessment

It is very important for a financial institution to get out in front of UDAAP compliance early. What to do first? A UDAAP Risk Assessment. The risk assessment will give you a good look at the changes you may need to make to comply. It will be a mistake to put this off.

We have programs and services that can help banks make the paradigm changes UDAAP will require. You can read our “Get Ready for UDAAP” client memo here.

The regulators have some definite expectations regarding a bank UDAAP compliance program.  Read more about that here: UDAAP Regulatory Expectations).

Want to get started? Here’s the next steps

1. Call to discuss your needs and to obtain our Certificate of Non-Disclosure and Privacy Agreement.
2. If we’re only spit-balling, than skip Step 3. We don’t charge for conferences or to share our experience.
3. Review our Fee Proposal. If it is acceptable, go to next step. NOTE: depending upon the circumstances, not all information request may be necessary. The rule of thumb: if you’re paying us, we want as much information as possible. If we’re just talking, then less information may be forthcoming.
4. Provide some information for our discussion session. Some, all or none of the below maybe appropriate.
   • Summarize examination comments (positive and negative) along with examiner recommendations and send those to us. Include in your summary both the written comments as well as any oral communication that took place. NOTE: we may not need to see copies of the actual comments; we can always review with a GoToMeeting session.
   • Gather up your current policy and procedures along with any documents you use to open accounts or perform the work. You can scan and email to our secure portal or fax them to us.
   • Gather your current reports you are using now to manage compliance.
   • Summarize your current monitoring efforts; provide copies of reports used.
5. We’ll send you a checklist you can use to help us understand the specifics of how you operate this part of the bank and how you are managing the compliance piece.
6. We’ll send you the “prelim” policy and procedure in a MS WORD format to review and revise.
7. We’ll schedule a follow-up phone conference to review your changes.
8. We’ll send the revised Policy and Procedure.
9. You provide credit card for our billing. (Payment by ACH and/or check is also acceptable.)

Go here to see our fees > > >

View or Download our UDAAP Guidance document.