Does anyone have any ideas, worksheets, etc. about how to audit for Reg AA and deceptive practices? Most of the compliance audit programs I've looked at have been silent on this issue.

When I was at a large bank, they had procedures for auditoring for Reg AA. We had to review documents (even though they were bank documents) for any issues, and interview staff regarding any procedures/practices along these lines. Sorry I do not have a copy of the audit procedures, but hope this helps.

Look at your examiner's exam program. You'll have to review contracts for prohibited clauses, ensure co-signer notices are provided, and ensure late fees are not pyramided. For marketing, info on deceptive advertising (which could be broadly defined) can be found on the FTC website. Your regulator may have their own rules barring deceptive advertising.

Thanks, ahou, that was exactly what I needed.

I am in the middle of a UDAP audit and used the audit procedures from the FDIC Compliance Manual, the OCC exam procedures, and the FTC Consumer Compliance Handbook. I figured if I refered to all three I would hopefully cover all my bases. I am also incuding some of the "hot topic" UDAP issues such as how we are handling excessive overdrafts and planning ahead for changes in lender compensation.