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#1599946 - 09/02/11 07:52 PM UDAAP
sewanee, CRCM Offline
Gold Star

Registered: 12/07/06
Posts: 405
Loc: TN
Does anyone have a reference for the new UDAAP regs? Is anything definite yet?
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#1599950 - 09/03/11 12:11 AM Re: UDAAP [Re: sewanee, CRCM]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50035
Loc: Galveston, TX
What new regulations are you referring too?
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The opinions expressed are my own, take them or leave them.

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#1599968 - 09/05/11 03:33 PM Re: UDAAP [Re: rlcarey]
Bullseye Offline
Platinum Poster

Registered: 01/27/04
Posts: 958
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 07:06 PM Re: UDAAP [Re: Bullseye]
Kathleen B Online

10K Club

Registered: 12/27/00
Posts: 17475
But there really is no new regulation...addition of abusive by Dodd Frank to Unfair and Deceptive. And stronger enforcement; much stronger enforcement.


Edited by Kathleen B (09/05/11 07:40 PM)
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Kathleen Blanchard CRCM "Kaybee"
Lending/CRA/HMDA/Mapping/Consulting
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#1600437 - 09/07/11 10:22 AM Re: UDAAP [Re: Kathleen B]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 907
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 10:52 AM Re: UDAAP [Re: lvc]
Pale Rider Offline
10K Club

Registered: 08/09/02
Posts: 33938
Loc: 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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The free enterprise system is the most productive supplier of human needs and economic justice in the universe!

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#1600496 - 09/07/11 11:35 AM Re: UDAAP [Re: lvc]
Ted Dreyer Offline
Diamond Poster

Registered: 04/05/01
Posts: 2211
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 05:11 PM Re: UDAAP [Re: Ted Dreyer]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 907
Does UDAAP apply to a Bank Holding Co?

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#1600835 - 09/08/11 09:05 AM Re: UDAAP [Re: lvc]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 907
Bump

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#1600905 - 09/08/11 10:22 AM Re: UDAAP [Re: lvc]
Ted Dreyer Offline
Diamond Poster

Registered: 04/05/01
Posts: 2211
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 01:51 PM Re: UDAAP [Re: Ted Dreyer]
lvc Offline
Platinum Poster

Registered: 07/11/07
Posts: 907
Thanks

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