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Managing UDAAP Compliance Risks in Financial Institutions  


Author:  Kathlyn L.  Farrell.


Source: Volume 27, Number 02, November/December 2013 , pp.21-34(14)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

Compliance with Unfair, Deceptive or Abusive Acts or Practices (UDAAP) principles has become a thorny problem for U.S. financial institutions. The UDAAP regulatory scheme, as embodied by the Consumer Financial Protection Bureau, represents a new approach to regulating financial institutions and the industry has yet to fully adjust. This article reviews the history of UDAAP regulation in the U.S. and then examines the ways financial institutions must change their compliance management programs to minimize the risk of UDAAP violations.

Keywords: UDAP; UDAAP; FTC Act; CFPB; unfair practices; deceptive practices; abusive practices; risk management

Affiliations:  1: Treliant Risk Advisors, LLC.

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