The Struggle of UDAAP

The struggle of UDAAP is that it lurks in the gray areas. When it comes to compliance, a lot of the time we have a law or regulation that spells out what we should or shouldn’t do and is pretty black and white. UDAAP isn’t like that. All we have to go on is the law. There is no regulation to set the framework and/or boundaries. That results in a lot of gray and invites some subjectivity on the part of your examiners when determining if something is unfair, deceptive or abusive. Even if you are following a regulation to a “T”, UDAAP can still come into play. Thus, it’s important to assess the risk and proceed accordingly.

Jerod explains more in the video.

 

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Published
2024/12/03
Jerod Moyer

Jerod Moyer

Jerod is the leader of Banker’s Compliance Consulting’s training productions. He is a nationally recognized speaker. Whether it’s a conference, seminar, school, webinar or luncheon, it’s easy to stay engaged when he presents due to the amount of passion and energy he brings to each and every compliance topic. Jerod has spoken on behalf of the American Bankers’ Association, BankersOnline, many state banking associations, private compliance groups and financial institutions. He is a Certified Regulatory Compliance Manager (CRCM) and BankersOnline Guru. Jerod likes to spend his time (between reading regulations and producing compliance training!) relaxing at the lake with his wife and three children, following their activities or engaged in something sports-related!

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The Struggle of UDAAP
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