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#1599946 - 09/02/11 11:52 PM UDAAP
Sewanee, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 435
TN
Does anyone have a reference for the new UDAAP regs? Is anything definite yet?
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#1599950 - 09/03/11 04:11 AM Re: UDAAP Sewanee, CRCM
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
What new regulations are you referring too?
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#1599968 - 09/05/11 07:33 PM Re: UDAAP rlcarey
Bullseye Offline
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Bullseye
Joined: Jan 2004
Posts: 968
Check BOL's Learning Connect. I believe I just saw that they have a webinar coming up on this topic.

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#1599972 - 09/05/11 11:06 PM Re: UDAAP Bullseye
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
But there really is no new regulation...addition of abusive by Dodd Frank to Unfair and Deceptive. And stronger enforcement; much stronger enforcement.
Last edited by Kathleen B; 09/05/11 11:40 PM.
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#1600437 - 09/07/11 02:22 PM Re: UDAAP Kathleen O. Blanchard
lucyc Offline
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lucyc
Joined: Jul 2007
Posts: 1,074
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?

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#1600457 - 09/07/11 02:52 PM Re: UDAAP lucyc
Pale Rider Offline
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Joined: Aug 2002
Posts: 34,318
under the Lone Star
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?
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#1600496 - 09/07/11 03:35 PM Re: UDAAP lucyc
Ted Dreyer Offline
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Ted Dreyer
Joined: Apr 2001
Posts: 2,245
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.

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#1600737 - 09/07/11 09:11 PM Re: UDAAP Ted Dreyer
lucyc Offline
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lucyc
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Posts: 1,074
Does UDAAP apply to a Bank Holding Co?

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#1600835 - 09/08/11 01:05 PM Re: UDAAP lucyc
lucyc Offline
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lucyc
Joined: Jul 2007
Posts: 1,074
Bump

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#1600905 - 09/08/11 02:22 PM Re: UDAAP lucyc
Ted Dreyer Offline
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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.

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#1601143 - 09/08/11 05:51 PM Re: UDAAP Ted Dreyer
lucyc Offline
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lucyc
Joined: Jul 2007
Posts: 1,074
Thanks

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