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#1719682 - 07/12/12 10:13 PM UDAAP Policy Required?
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
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.
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General Discussion
#1719727 - 07/13/12 01:09 PM Re: UDAAP Policy Required? Sunshine_101
#Just Jay Offline
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#Just Jay
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Cheeseheadland
No, one is not required.

Some are creating such policies while others are injecting short verbiage into existing policies where it seems logical to do so.

I think it is smart to address UDAAP in some shape or form, but your bank size, product mix and complexity should guide you to which way is most appropriate for your shop.
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#1719802 - 07/13/12 02:29 PM Re: UDAAP Policy Required? Sunshine_101
DeeQ Offline
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DeeQ
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Turnpike Exit 10
Originally Posted By: INeedaXanax
It is not required, but in light of the super pro-consumer environment, it may be prudent. smile
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#1719817 - 07/13/12 02:54 PM Re: UDAAP Policy Required? Sunshine_101
manimal Offline
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manimal
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If you decide not to do a separate UDAAP policy, I highly recommend a UDAAP Risk Assessment. This is what we did, and then our existing policies address UDAAP in one way or another as applicable.
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#1719858 - 07/13/12 03:32 PM Re: UDAAP Policy Required? manimal
Sunshine_101 Offline
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Sunshine_101
Joined: May 2005
Posts: 127
Thanks for all your responses, very helpful! smile
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