Banker's Compliance Consulting Blog

UDAAP: The Four Ps of Deception

Written by Kevin Edwards | Aug 11, 2026, 7:14:59 PM

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.

Published 2026/08/11