We included this area in our most recent internal audit risk assessment and I plan on using the CFPB audit checklists to start.. Has anyone performed one of these reviews and would you have a sample audit report that you would be willing to share.

Hopefully, it will be blank.

yes, fortunately it is... just curious what others are covering in their reports

Well, the scope of you review - so without know what you looked at, it is hard to say. The report would really not be formatted any different than any other audit report.

It will likely be a massive scope if you think about the fact that UDAAP can touch potentially anything in the bank. I include a UDAAP section in each audit I perform which would determine whether or not that area (whatever the audit is at the time) has identified any UDAAP issues.

I do the same as Norman. Each audit includes UDAAP.

Our compliance auditors perform a UDAAP review in each audit performed. Prior to outsourcing our compliance audits, we were going to perform a UDAAP audit and determined it was to massive to perform as a stand alone audit.

OSUCPA, mind if I ask how big your institution is? I went to a state banking association conference recently and heard a number of smaller institutions say that they essentially outsourced their compliance function (policy and audit) to third party consultants.

Maybe I need to start Moonlight Compliance, LLC â„¢

â„¢ - I will sue.

We are a 1.5 billion dollar retail driven bank.

For those of you that include a UDAAP portion in each audit... how do you address it in the report? Do you say you tested xyz area and found no issues related to UDAAP or something else -this is more my question I guess.

We are a small commercial bank with very little in the way of consumer activity, no credit cards, no advertising, no mortgages, very limited number of consumer HELOC's, limited number of complaints, we do have some consumer checking, MMDA and certificate accounts etc. no overdraft programs... not zero potential but definitely in the minority based on our client base and product offerings.

I used the CFPB audit section out of their manual as a scoping tool .....so if I audited deposit operations and found no UDAAP issues.. that would be sufficient coverage in your report in your world?