UDAAP: Risk Assessment, Examination Procedures and Management

Advances in banking technology and changes in lending organization structure since Gramm-Leach-Bliley have permitted institutions to engage in non-banking activities and given banking organizations the ability to structure financial products in increasingly complex ways and to market such products with increasingly sophisticated methods. While most banking organizations do not engage in unfair or deceptive acts or practices (UDAPs), the pace and complexity of these advances heighten the potential risk for consumer harm. This potential risk, coupled with identified abusive practices, warrants increased scrutiny by the FDIC and state and federal enforcement agencies. UDAPs are illegal; can cause significant financial injury to consumers; erode consumer confidence; and present significant credit and asset quality risks, undermining the financial soundness of banking organizations.

Covered Topics:

  • Standards for Determining What is Unfair or Deceptive
  • Unfair Acts or Practices
  • Public Policy May be Considered
  • Deceptive Acts or Practices
  • Complaint Resolution Procedures
  • Sources for Identifying Complaints
  • Analyzing Complaints
  • Relationship to Other Laws
  • Privacy of Consumer Financial Information
  • Risk Assessment Procedures
  • Transaction-Related Examination Procedures 
  • Relevant marketing and advertising materials, including website pages
  • Relevant disclosures and customer contracts

Who Should Attend?

The program is designed for Risk Officers, Compliance Officers, Fair Lending Officers, Auditors, Management and supporting staff members of those departments.