Answer:
In one enforcement case, the bank's third party vendor processed unauthorized remotely created checks. Because the bank should have recognized the fraud and it failed to act, the bank was hit with a UDAP action. In addition to other penalties there was restitution ordered of $125 million. Other cases involve credit cards and a $6 million restitution and reserve settlement, another was $4 million. The list goes on.
The key is to not start down the path toward a systemic problem that can trigger these types of actions.
Learn more about Andy’s webinar UDAAP Reality Check.
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