UDAAP, the Risk is Real - 2019
Presented by
Andy Zavoina
Recorded on December 5, 2019
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2.0 hours
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You can’t avoid accusations of UDAAP unless you know what it means. We will explore what makes a practice unfair or deceptive by digging into what regulators and the courts have had to say. We will review the teeth Congress gave to the area when it expanded UDAP to include the second “A” -- “Abusive” to better protect consumers. We’ll review the definitions that must be used for UDAAP, and what it all means to your bank on a day-to-day basis.
We will explore the role of compliance auditing in the risk management program that will help keep you out of hot water. A core element to prevention is to “nip it in the bud” and that means monitoring complaints, analyzing them at a manager’s level and properly responding to them. Effective complaint management is vital to avoiding that dreaded term examiners use - “a pattern or practice” of doing something that harms your customers. It could be unintentional and subjective. But recognizing and understanding the perception is key.
We will review actual enforcement actions published by regulatory agencies that affect financial institutions of all different sizes. You’ll learn that UDAAP may be the enforcement vehicle a regulator chooses simply because it has more teeth than a specific regulation.
BONUS: Webinar participants will receive a Complaint and Inquiries Policy template as part of the course materials.
Andy Zavoina
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