Hoping someone can help me understand what relationship there is, if any, between Reg. AA (Credit Practices Rule -- Unfair and Deceptive Acts and Practices) and the UDAAP guidance coming out of Dodd-Frank. My belief at this point is that the UDAAP guidance in Dodd-Frank does not currently have any effect on what's contained in Reg AA. Is that correct?

Have rules/regulations around UDAAP been issued? If so, can you tell me where? And will these eventually impact Reg. AA? Thanks.

I don't believe that any rules/regulations surrounding a new Reg AA have yet been issued by the Bureau. This thread may be useful:

UDAAP

You can review the CFPB Exam Manual on UDAAP, along with a helpful narrative, here:

http://www.consumerfinance.gov/guidance/supervision/manual/

Thank you both for your input.

So am I safe in saying that there have been no changes, at this point, to Reg. AA as a result of anything out of Dodd-Frank? It is time for me to review and update our Reg. AA policy. and I am not aware of any changes to Reg. AA over the past year. But some within our bank are saying that it needs to be updated due to the UDAAP changes out of Dodd-Frank that become effective 12/1/11.

First, I am not aware of UDAAP changes that become effective 12/1/11. Have I missed something here?

Secondly, even if there are new UDAAP rules effective 12/1/11, I don't believe they would have any impact on our Reg. AA policy, which strictly focuses on the content and provisions in Reg. AA.

Am I thinking correctly here? Thanks.

You are thinking correctly. Reg AA currently remains unchanged.

I am still a little confused. Are we to follow UDAAP as noted at this link: Consumer Laws and Regulations: Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) > Consumer Financial Protection Bureau. When was it effective? Reg AA remains unchanged?

Since the CFPB did not list Regulation AA in the published list of regs transferring to the CFPB from the FRB, some think that Reg AA was effectively repealed by Dodd-Frank's repeal of Section 18(f)(1) of the Federal Trade Commission Act (which empowered the Fed to issue Reg. AA). On the other hand, the FTC's Credit Practices Rule and Telemarketing Sales Rule did transfer to the CFPB, as did rulemaking authority for UDAAP. This summary might help http://www.ballardspahr.com/alertspublic...y_the_cfpb.aspx