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I have done a quick review of the UDAAP information that Jack provided to us in the last webinar and I am really struggling with the best option of how to complete procedures. On the one hand, it would be great to have them broken down by product/service; however, I think this would be a monster procedure for our bank if that were to happen. It may make more sense in our case to break it down by department but then I am concerned that I will overlook something. Anyone else have any thoughts? We do not have a policy or procedure currently in place for UDAAP and this is going to be on my radar for the first quarter of 2012.
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