UDAAP is a concern if your marketing or employee communication to your customers about the product is unclear or if you advertise benefits that your customers never receive. If you see an uptick in consumers below the age of 55 complaining about the product because from your ad their inferred it was free to them, or they claim staff told them it was free, you have a UDAAP concern. If your customers over 55 wind up paying service fees because you system was not configured correctly to waive fees or staff steered the customers into a higher priced product because they received greater incentives for higher priced products, then you have a UDAAP concern.
The product itself would not lead to a UDAAP citation, but as with any bank product, clearly say what you do and do what you say.
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