How to Develop a UDAAP Compliance Management System

Regulatory agencies have been placing increased attention on UDAAP, and that attention is expected to increase. A well-developed Compliance Management System prevents UDAAP problems.

The rules related to Unfair, Deceptive or Abusive Acts or Practices (UDAAP) affect every product or service offered by your bank. The Dodd-Frank Act recently expanded the topic from UDAP to UDAAP by adding rules for abusive acts or practices. Regulatory agencies have been placing increased attention on the topic for several years and that attention is expected to increase over the next several years. The purpose of this program is to help you to develop a complete compliance management system (CMS) for UDAAP.


  • How to:
    • Develop a UDAAP risk assessment;
    • Develop a UDAAP policy and procedures;
    • Conduct and document UDAAP training; and
    • Develop and maintain a UDAAP internal audit/review program
  • Frequently cited UDAAP violations from the list developed and maintained by Bankers Service Corporation.


Everyone in your institution including, but not limited to operations, new accounts, lenders, marketing, compliance officers, and auditors.


Jack Holzknecht, CRCM, a principal with Pegasus Educational Services, LLC, has has been delivering the word on lending compliance for 37 years. Jack’s career began as a federal bank examiner. He also headed the form and software division of a regional consulting company and spent seven years in charge of their education division. He also developed and delivered training for the FDIC and OTS.

Matt Evans is the President and CEO of Bankers Service Corporation. Matt helped form Bankers Service Corporation in 1997. In addition to overseeing daily operations of the company, he is involved in loan review, compliance audit, internal audit, training, and consulting . Prior to joining BSC, Matt was an Examiner with the FDIC.

Credit Information

Institute of Certified Bankers: Visit aba.com/icb/membercereview for instructions regarding self-reporting. Estimated credits: 2.5 hrs./session CLBB/CRCM/CPB/CCSR..


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