The Difficulty of UDAAP

We all know that compliance isn’t always black or white. Situations often arise that fall in that gray area and that gray area can lead to uncertainty. There is nothing more “gray” than Unfair, Deceptive and Abusive Acts or Practices (UDAAP). You can get into a lot of trouble for things deemed to be unfair, deceptive, abusive, etc., but there really isn’t a lot of concrete guidance out there to go on. So much of UDAAP is in the eye of the beholder, meaning your examiners.

Jerod explains more in the video.

Video Highlights:

• UDAAP risk lies in the gray areas, where no formal rules have been established.
• Interpretation is often subjective, leading to inconsistent application or enforcement from one examiner to the next.
• UDAAP risks can arise when there is more flexibility to make decisions.

Published
2023/11/30