Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) can pop up just about anywhere within an institution. However, your marketing and/or advertising efforts can lead to a hotbed of problems if you don’t take appropriate measures. In fact, the OCC’s UDAAP Handbook states:
Inadequate oversight and review of advertisements, marketing materials and scripts, and sales practices could increase UDAP and UDAAP risks by not identifying when information marketed or communicated to consumers is misleading, difficult to understand, or differs from actual disclosures or the functionality of a product or service.
Problems can also arise with targeted internet marketing campaigns and fair lending. We highly recommend you read the Consumer Compliance Outlook (Third Issue 2019) article, From Catalogs to Clicks: The Fair Lending Implications of Targeted, Internet Marketing.
Jerod explains more in the video.
Published
2024/11/18
