Four Letter Word…****!

UDAP!  Lately, the mere mention of this term gets my attention very quickly.  The Federal Trade Commission’s Unfair or Deceptive Acts and Practices BSA Training and Banking Regulations Compliance Consulting jerod11 - Four Letter Word...****!(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:

  1. Protect the consumer!
  2. Regulators think they are getting better at applying the UDAP concept -yikes!
  3. Watch out for the following:
  • Posting debit transactions from high dollar amount to low dollar amount
  • Mortgage pre-qualification and pre-approval letters language

Jerod Moyer

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