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

Registered: 12/07/06
Posts: 398
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: 48524
Loc: Galveston, TX
What new regulations are you referring too?
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#1599968 - 09/05/11 03:33 PM Re: UDAAP [Re: rlcarey]
Bullseye Offline
Platinum Poster

Registered: 01/27/04
Posts: 942
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: 16547
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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#1600437 - 09/07/11 10:22 AM Re: UDAAP [Re: Kathleen B]
lvc Online
Platinum Poster

Registered: 07/11/07
Posts: 889
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 Online
10K Club

Registered: 08/09/02
Posts: 33848
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 law kills, but the spirit gives life....

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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: 2199
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 Online
Platinum Poster

Registered: 07/11/07
Posts: 889
Does UDAAP apply to a Bank Holding Co?

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

Registered: 07/11/07
Posts: 889
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: 2199
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 Online
Platinum Poster

Registered: 07/11/07
Posts: 889
Thanks

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