When we prepare our UDAAP scope we look at a few different sources to determine our scope.
CFPB's Supervisory Highlights
Our own UDAAP risk assessment
Industry enforcement trends
Prior reviews which returned significant findings
Prior examinations where weaknesses were identified
Other areas of the Bank which may not receive detailed attention during routine Compliance reviews
As you said, UDAAP touches everything from marketing, to development of products, to rollout; from the teller line to Executive Management. Its potential exists ubiquitously throughout the Bank, so any area you feel you may need to review is likely the right area to review. Best of luck!
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I reject your reality and replace it with my own.