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The State of UDAAP: Where Are We Now?

In this webinar we’ll discuss understanding what examiners are focusing on, including areas where a clear rule or regulation might not even apply. This has been a major cultural shift in the regulatory function, and we’ll delve into how to identify UDAP/UDAAP, how to monitor and test for it, and where particular risks are found, among other topics.

OnDemand
Recorded Friday,
December 20th, 2024
Presented by Carl Pry
2h total length
2.5 CRCM & 2.5 CERP Credits
$299.00 or 1 Token

Includes: 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Compliance
  • Lending
  • Lending Compliance
  • Management/Employee Development
  • Bank Legal Counsel
  • Board Member
  • Compliance Officer
  • Consumer Lender/Retail Banker
  • Risk Manager
  • Senior Management
  • Training Manager
  • Trainer

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The terms “UDAP” and “UDAAP” are perhaps the most significant ever to affect compliance. That sounds pretty bold, but consider that the CFPB was given an almost-unlimited mandate under Dodd-Frank to “take any action… to prevent a covered person or service provider from committing or engaging in an unfair, deceptive, or abusive act or practice under Federal law in connection with any transaction with a consumer for a consumer financial product or service, or the offering of a consumer financial product or service.”

Although the UDAAP standard seems new, we’ve actually been familiar with “UDAP” (just one ‘A’) for quite some time. That extra ‘A’ (for ‘Abusive’) added a new standard, however, and the CFPB and the regulators have been active with criticisms and enforcement actions. UDAP/UDAAP has been applied in almost every setting, including commercial customers and transactions.

You must be familiar with what this new standard means for compliance and the risk management process. Technical compliance is no longer the only issue to be concerned about, as UDAP/UDAAP can found even though every technical compliance requirement may have been strictly followed.

What You'll Learn

  • UDAP vs. UDAAP: What did the introduction of “abusive” really do? Guidance and advice
  • The reach of UDAP/UDAAP: It isn’t only a CFPB issue – it affects ALL institutions, regardless of regulator
  • “Abusive” standards: How is this being enforced?
  • Scope of UDAAP: Products, services, delivery channels, and methods
  • Examples of practices, as well as high-risk products and services: Where should your focus be?
  • The concept of “UDAAP Risk” – How to handle it?
  • Possible expansion of the UDAAP concept: “Discrimination is UDAAP”
  • Emphasis on sales and marketing practices, and product management
  • Cultural change brought by UDAAP
  • Areas where you wouldn’t even think to look
  • Can treating a customer more favorably be unfair?
  • How to prepare your UDAAP program
  • What are the regulatory expectations? Evaluations, risk assessments, more?
  • Going beyond the program: Managing the culture of your organization

Who Should Attend

UDAAP is an issue that affects most everyone in the financial institution, but in particular, compliance officers, auditors, management, counsel, marketing, sales, product development, business line management, and anyone else involved in any products, services, or practices that impact consumers will get valuable information from this webinar.

Carl Pry

Instructor Bio

Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Advisor for Asurity Advisors in Washington, DC. Through his more than 30-year working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves as the Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.

Continuing Education Credit Information

The State of UDAAP: Where Are We Now? has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.

The State of UDAAP: Where Are We Now? has been approved for 2.5 CERP credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.

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