UDAAP Policy
This UDAAP Policy addresses how a bank, credit union, fintech company, or other type of financial institution mitigates potential risks posed by unfair, deceptive, or abusive acts and practices (UDAAPs) under federal regulatory guidelines. UDAAPs can cause significant financial injury to consumers, erode consumer confidence, and undermine the financial marketplace. Under the Dodd-Frank Act, it is unlawful for an organization as a provider of consumer financial products or services or a contractual service provider of the organization to engage in any UDAAP.
Table of Contents
- Purpose and Contents – Topic 1
- Policy Statement – Topic 2
- Definitions – Topic 3
- Risk Management – Topic 4
- Structure of Accountability and Responsibility – Topic 5
- UDAAP Compliance Program – Topic 6
- Red Flags – Topic 7
- Consumer Complaints – Topic 8
- Bank Operations – Topic 9
- Relation to Other Laws and Regulations – Topic 10
- Audit Policy – Topic 11
- Staff Training – Topic 12
- Retention of Documentation – Topic 13
Recent updates to this product:
12/16/24 Update
OCC Bulletin 2024-33 – Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices: Updated Comptroller’s Handbook Booklet and Rescissions
06/17/24 Update
CFPB Circular 2024-03 – Unlawful and Unenforceable Contract Terms and Conditions
04/15/24 Update
CFPB Circular 2024-02 – Deceptive Marketing Practices About the Speed and Cost of Sending a Remittance Transfer
06/01/23 Update
CFPB Circular 2023-02 – Reopening Deposit Accounts That Consumers Previously Closed
04/17/23 Update
CFPB – Policy Statement on Abusive Acts or Practices
04/03/23 Update
CFPB Bulletin 2023-01 – Unfair Billing and Collection Practices After Bankruptcy Discharges of Certain Student Loan Debts
02/01/23 Update
CFPB Circular 2023-01 – Unlawful Negative Option Marketing Practices
04/04/22 Update
CFPB Release – CFPB Targets Unfair Discrimination in Consumer Finance
CFPB Release – CFPB Issues Policy on Contractual ‘Gag’ Clauses and Fake Review Fraud
03/15/22 Update
CFPB Bulletin 2022-04 – Mitigating Harm from Repossession of Automobiles
This UDAAP Policy (approximately 54 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
Product Update Protection Plan
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