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.