Does anyone have a UDAAP policy that they are willing to share?

That a pretty broad subject........ How you would write a policy to cover every possibility would be impossible.

How about:

It is the policy of this bank not to engage in any activity that could be perceived as being unfair or deceptive.

Other than that - good luck......

What you might want, besides a policy statement, is a procedure that lays out what steps the bank takes to avoid/prevent UDAAP isses...ad reviews before publication, new product approval process, etc.

I would not be comfortable making a blanket promise not to do anything that some third party using their own yardstick could call unfair, abusive, or deceptive. What I might be willing to do is establish a tangible complaint process that I would commit to continuously reviewing for practices that might be so labeled.

Yes, complaint monitoring for trends and specific cases is a major part of a UDAAP management "process".

Thanks for your responses...I intend to format the policy based off of the regulator's exam procedures, but did not want to re-invent the wheel if someone already had that all laid out in policy format.

Anyone??

You're making a serious mistake to be specific. One thing you can, and should, do is tie this policy to your ethics policy. In fact, you might want to consider expanding your ethics policy instead of creating a new trap that will certainly catch you by surprise at some point in the future. No one (I hope) plans to do things that are unfair, deceptive, or otherwise injurious to their customers, but as Ken correctly observes, "fairness" is subjective.

Here's news that shouldn't come as a shock: The UDAAP rules are intentionally vague, so the Feds can interpret any regulation any way they want and rule by fiat depending on which way the political wind blows. We as bankers get so conditioned to jumping through hoops to comply with vaue "guidances" and "commentaries" government agencies who are run by 23-year old Harvard MBA's who have no idea how the real world works, I sometimes worry that we never stop to as "unfair or deceptive to whom??" Writing a policy for UDAAP is impossible. The best you can do, which is our philosophy, is to do right by your shareholders and customers and obey the law at the same time. Nothing else matters.

A good place to start would probably be the exam procedures the CFPB put out. They have guidance as well.

Is a policy required by any law or regulation? If it is required could you please offer a cite? Thanks in advance for any answers.

It is not required, but in light of the super pro-consumer environment, it may be prudent.

Easier said than done. The entire "fair lending" mantra rests on subjective framework. See HUD's latest on "dissparent effect". DFA and UDAAP are very volitile mixtures.