Does anyone have a reference for the new UDAAP regs? Is anything definite yet?
Posted By: rlcarey
Re: UDAAP - 09/03/11 04:11 AM
What new regulations are you referring too?
Posted By: Bullseye
Re: UDAAP - 09/05/11 07:33 PM
Check BOL's Learning Connect. I believe I just saw that they have a webinar coming up on this topic.
But there really is no new regulation...addition of abusive by Dodd Frank to Unfair and Deceptive. And stronger enforcement; much stronger enforcement.
Posted By: lucyc
Re: UDAAP - 09/07/11 02:22 PM
Our bank has less than $10 billion in assets therefore we will not be directly regulated by the CFPB.
That being said, should we update our UDAP policy to include abusive and reference to Dodd Frank Title X?
Posted By: Pale Rider
Re: UDAAP - 09/07/11 02:52 PM
It all comes down to common sense. Would you allow or want your children to take out a loan with the same terms and conditions as you are offering this third party?
Posted By: Ted Dreyer
Re: UDAAP - 09/07/11 03:35 PM
lvc: Yes, you probably should. The CFPB is not only given the power under section 1031 of the DFA to issue regulations on UDAAP covering consumer financial services providers but has enforcement power in that area as well.
Posted By: lucyc
Re: UDAAP - 09/07/11 09:11 PM
Does UDAAP apply to a Bank Holding Co?
Posted By: Ted Dreyer
Re: UDAAP - 09/08/11 02:22 PM
It does if the holding company either engages in offering or providing consumer financial services or if it acts as a service provider to institutions that do.