Four Letter Word...****!
By Jerod Moyer
UDAP! Lately, the mere mention of this term gets my attention very quickly. The Federal Trade Commission's Unfair or Deceptive Acts and Practices (UDAP) seems to be the "go to" for regulatory agencies. Especially when there isn't a specific regulatory reference for something the bank's doing or involved in that they don't like. At the ABA Conference in June the message from the regulatory agencies was quite clear:
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Protect the consumer!
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Regulators think they are getting better at applying the UDAP concept -yikes!
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Watch out for the following:
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Posting debit transactions from high dollar amount to low dollar amount
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Mortgage pre-qualification and pre-approval letters language