The State of UDAAP: Dealing with a New Reality
How to Prepare and Manage the Risk
“UDAAP” could become the most significant term ever to affect bank compliance.
That sounds pretty bold, but consider that the CFPB has been given an almost-unlimited mandate under Dodd-Frank to “take any action…to prevent a covered person or service provider from committing or engaging in an unfair, deceptive, or abusive act or practice under Federal law in connection with any transaction with a consumer for a consumer financial product or service, or the offering of a consumer financial product or service.”
Although the UDAAP standard seems new, we’ve actually been familiar with “UDAP” (just one ‘A’) for quite some time. That extra ‘A’, for ‘Abusive’, adds a new standard, however, and the CFPB is already active with enforcement actions.
What does all this mean to banks and the industry? At the very minimum, it means you must be familiar with what this new standard means for compliance and the risk management process. The rules of the game have changed, and technical compliance is no longer the only issue.
It means understanding what examiners are likely to focus on, including areas where a clear rule or regulation might not even apply. It’s a cultural shift in the regulatory function, and in this webinar we’ll discuss the meaning of UDAAP and how it will impact your bank.
- UDAP vs. UDAAP: what does the introduction of “abusive” really do?
- This isn’t only a CFPB issues – it will affect ALL banks, regardless of regulator
- “Abusive” standards: how will this be enforced?
- Scope of UDAAP: products, services, delivery channels and methods
- UDAAP examples: where should your focus be?
- Emphasis on sales and marketing practices, and product management
- Cultural change brought by UDAAP
- What are the agencies looking for?
- Areas where you wouldn’t even think to look
- How to prepare your UDAAP program
- What are the regulatory expectations? Evaluations, risk assessments, more?
- Going beyond the program: changing the focus of your organization
UDAAP is an issue that affects most everyone in the financial institution. But in particular, compliance officers, auditors, management, counsel, marketing, sales, product development, business line management, and anyone else involved in any products, services, or practices that impact consumers will get valuable information from this webinar.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at dozens of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CFMP & CRCM Credits
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