I am still a little confused. Are we to follow UDAAP as noted at the link below. When was it effective? Reg AA remains unchanged?

My bank is a small FSB

http://www.consumerfinance.gov/guidance/supervision/manual/udaap-narrative/

You should absolutely be following UDAAP... think of it like the golden rule of consumer protection... no matter what is on the books in terms of a Regulation... UDAAP will reign supreme.

Consider the anecdotal stories that are floating in the industry about Reg E compliance being trumped by UDAAP.

However, don't panic, if you're bank isn't doing anything over the top to harm customers UDAAP isn't as scary as some in the industry believe it to be... unless of course you are trying to be deceptive, and abusive in your acts and practices.

Cheers!