Not sure where to post this question...

I am wanting to try and do a review on our bank for UDAAP. Does anyone know if the regulators are focusing in on this or would this be a waste of my time? Should we have some sort of UDAAP policy and/or formal procedures?

Send me a PM with your email address.

I am sitting in on the 2012 Lending Compliance Conference and sat up and took note on UDAAP(must be said like a sheep for full effect)

I immediately looked up:
http://www.consumerfinance.gov/guidance/supervision/manual/udaap-examination-procedures/

and became the lucky recipient of some very wonderful information.

With reference to ackcompliance's questions, we would also like to review our bank for UDAAP.

Question: What is the most effective way to go about this? Do you include a section in each audit for UDAAP or should it be a stand alone audit encompassing everything? Personally I think this should be an additional section in each audit based on the guidance given in the UDAAP examination Procedures link listed above.

What are your thoughts?

We did it in two waves. First we completed a UDAAP risk assessment using the exam procedures you provided a link to. This provided us with several 'high risk' areas we needed to make some improvements in. Then, separately, I address UDAAP in my regular periodic monitoring as you described--built into each section of the audit (lending, deposits, etc.).

I hope this helps!

Thank you manimal. After reading your post, I spoke to our Compliance Officer about doing a RA to get the ball rolling on this.

Would anyone mind sharing their RA for UDAAP just to help get started?

Look at the FDIC Compliance Exam manual.

^^ Ditto. And the CFPB exam procedures mentioned above, that is what I used to set the framework for ours.

Is anyone else having some trouble with the CFPB website? I keep getting an error message.

I was able to get to the examination manual without any trouble. Is that where you are looking?

Nope:

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

This is the error message I get from CFPB:


An error occurred while processing your request.
Reference #97.76fc4317.1349895887.3580eff2

I clicked on the link Randy provided and got right to the examination manual. Try again, if it doesn't work you may want to check with your IT staff to see if there is a problem on your end.

MrsPotatoHead
I have the same problem and it is because our IT Department blocks any sites hosted in a foreign country. Apparently the IP address for the CFPB is hosted somewhere outside the US. It has been a challenge for the Compliance Dept. when we've needed to look at the CFPB site. We've had to go to other sites, when available, to view the information. And, yes, Management supports the IT Department's decision. Fortunately, we won't be examined by the CFPB.

I am not a fan of compliance and BSA being blocked with the rest of the bank. See if they can provide a standalone laptop not behind the firewall to allow access to "forbidden" sites.

You might not be examined by the CFPB but you need to know what they are saying and doing as that will affect how you are examined.

Interesting. I don't know where your IT department gets its information, but my IP search for consumerfinance.gov reveals it's a US-located IP via a company located in Cambridge, Massachusetts. I know we are a left-leaning state on the right coast, but last I knew, we were still one of the original 13 states and haven't seceded from the union yet.

I think they may have been inundated with so many requests; the site may have shut down. Anywhoooo I got in and signed up to receive updates. All is right with the world.

They have masked the actual origin so it shows that it is in Mass, when it is in fact not there...

Anyhow
A good UDAaaP test (if you can do it) would be to make list of your customers then add a column for the different types of income you receive from them such as interest, fees, service chagges, etc. Then sort each column and see what comes up.

Give it the "would I be ok if my mother paid this" test.

Bankers Service Corporation posted a list of known UDAAP issues as of 11/21/12 (link to their PDF below). It might be helpful for some people.

http://www.bankersservice.com/wp-content/uploads/2010/08/Known-UDAAP-Examples-2012.pdf

BSC prepared a wonderful list (we're their clients). I'm sending it to our Board on Tuesday for training purposes.