UDAAP (Unfair, Deceptive, or Abusive Acts or Practices) risk is always lurking in the shadows just waiting to catch financial institutions off guard. Any time an advertisement goes out, a new product/service is offered, changes are made to an existing product/service, etc., institutions need to view those through a UDAAP lens. UDAAP is very subjective, for example, so what constitutes being “unfair” can look different from one person to the next. Often times, financial institution employees know too much and what seems obvious or understood to them may not be for a reasonable customer.
Jerod explains more in the video:
Published 2026/07/29