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#2012243 - 05/05/15 08:30 PM Difference between UDAP and UDAAP
Anonymous
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Is there a difference between these two? Should I replace UDAP with UDAAP wherever it is mentioned in my bank policies and procedures?

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#2012259 - 05/05/15 08:59 PM Re: Difference between UDAP and UDAAP Anonymous
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
UDAP is an acronym for "unfair or deceptive act or practice," a phrase in section 5 of the Federal Trade Commission Act.

Congress gave the CFPB authority to define practices within its sphere of influence that are "unfair, deceptive or abusive acts or practices" (UDAAP). The CFPB has used the FTC's guidance on what makes a practice unfair or deceptive, and added its own spin on what's abusive.

UDAAP is UDAP plus.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2012527 - 05/06/15 07:10 PM Re: Difference between UDAP and UDAAP Anonymous
NotALawyer Offline
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NotALawyer
Joined: Nov 2001
Posts: 455
I concur with the esteemed Mr. Burnett and would add, it depends on which applies to your institution - FTC Act Section 5 or the CFPB.

Just be sure to use the right pronunciation. UDAP = "You - dap" vs. UDAAP = "You - da - app" (with a Southern drawl.)

(edited for speling)
Last edited by NotALawyer; 05/06/15 07:11 PM.
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#2012536 - 05/06/15 07:18 PM Re: Difference between UDAP and UDAAP Anonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,704
Cape Cod
speling? Reely? LOL!
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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