Description:
While the CFPB rescinded a number of guidance documents, many of which were used to levy unfair, deceptive, abusive acts and practice accusations against financial institutions, the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
Presenters:
Brian Crow, CAMS
Brian Crow is managing partner and co-president for TCA Compliance and is a nationally recognized BSA/AML expert with a strong bank compliance management background and a welcome ability to provide focused educational support to TCA client banks. Crow most recently was BSA Administrator for a suburban Chicago bank, where his responsibilities included the bank’s annual assessment and audit documentation. Earlier, as Operations Officer at the same bank, Crow monitored AML activity and helped install automated AML software that allowed the bank to transition from paper to electronic CTRs. His activities were responsible for reducing debit card fraud by 95 percent at the bank. Mr. Crow has been, and continues to be, an education consultant for the Glia Group BOL Learning Connect program. It was in this role that Crow was recognized as a Bankers Online Guru in 2011. Like many of us, Mr. Crow began his banking career as a teller, working his way up to branch management responsibilities. He earned a B.A. degree from Concordia University, River Forest Illinois.
September 9, 2026