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.
Published
2024/12/03