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UDAAP, Cons., CML, All the Above

Answered by: 

Does UDAAP apply to just consumers, or all customers?

UDAAP rules are targeted to protect your consumer customers, but the reputation and financial risk of being accused of abusing commercial customers would be damaging. It is always prudent to follow the spirit and intent for all customers. The SBA PPP loan program is an example of that as class action lawsuits were filed the first day the program opened, and those were commercial loans.


Learn more about Andy Zavoina’s Understanding UDAAP/UDAP and Complaints webinar.

First published on 04/04/2021

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