UDAP/UDAAP: It Can Happen Anywhere

While the CFPB rescinded a number of guidance documents, many of which were used to levy unfair, deceptive, abusive acts and practice accusations against financial institutions, the legal, financial, and compliance risks have not gone away completely. Examiners stated that they will continue to cite instances of actual consumer harm but will limit enforcement of “potential harm.” Subsequent regulation will occur via the traditional rule making processes rather than regulation by enforcement.

While regulatory rollbacks come as a welcome change for the industry, we still must have an adequate compliance management system to identify products, services, and processes that have increased UDAP/UDAAP risk. This session will assist compliance and audit in identifying and mitigating the risks associated with non-compliance and ensure that our program is satisfactory today and, in the future, when the regulatory pendulum swings in the other direction.

Key takeaways:

• Identify UDAAP Risks
• Identify where and how UDAAP issues can occur
• Develop risk mitigation strategies
• Evaluate the effectiveness of compliance management
• Review UDAAP enforcement actions to aid in risk management