UDAAP: The Four Ps of Deception

UDAAP (Unfair, Deceptive or Abusive Acts or Practices) compliance can be a challenge because it’s very subjective. A statement in an advertisement or introducing a new fee on an account may seem perfectly fine on the surface but your examiners might see it differently. Determining whether something is deceptive or not often comes down to the four Ps of deception. These include:

  • Prominence
  • Presentation
  • Placement
  • Proximity

Kevin explains more in the video.

UDAAP Training!

Published 2026/08/11

Kevin Edwards

Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).

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UDAAP: The Four Ps of Deception
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