[rcooper]

I’m not aware of regulatory guidance that requires a stand-alone risk assessment for UDAAP. With that said, I do believe a UDAAP risk assessment is expected by examiners, shows your institution takes UDAAP seriously and finally, it is important for comprehensively evaluating UDAAP risk institution-wide. UDAAP should also be incorporated into other risk assessments as necessary.

[Author]

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