UDAAP, Cons., CML, All the Above

Answered by:

Question:

Does UDAAP apply to just consumers, or all customers?

Answer:

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. An FDIC enforcement action went against a bank for leases and fees charged by a subsidiary.

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