First, just want to say that these materials are great! I finally had the opportunity to review today and feel that this will help me get UDAAP policies and procedures implemented at my bank without having to jump off the roof!
Just wanted to provide a few questions or comments that I had as I progressed through the material:
1. Is there a need to put a UDAAP section in other policies that reference the fact that UDAAP policies and procedures exist, once these are implemented? The act of getting a policy approved in our bank takes quite a few steps and we are beginning a new year of taking policies to board so would like to know if this is something we should build into other policies as a reference.
2. Just as a comment, anytime we have a large change with policies/procedures in our bank, we have begun to setup an “Alliance” for whatever the subject matter is. This allows us to draw people in from other areas of the bank so that those areas affected are aware and take part in the change. I am leaning toward a UDAAP Alliance for this to be able to review all existing products/services! In other words, compliance is everyone’s responsibility, don’t do it alone! 🙂
3. Does anyone currently have a complaint/resolution policy/procedure that they don’t mind sharing? We have minimal procedures but I would like to have something more substantial in order to provide some consistency across all banking centers and management and would like to have this as part of this UDAAP project.
4. In the procedures, do you see the “Control” function as a Compliance function in your bank?
Thanks in advance for help and feedback!