Recent UDAAP penalties mean that the board and senior management must have a plan to monitor any potential issues. The CFPB required a $2 million refund and a $200,000 fine for deceptive advertising of free checking in an October 2014 action. Of the 40+ enforcement matters made public by the CFPB, half have alleged violations of the UDAAP provision of the Dodd-Frank Act. These actions have resulted in consumer restitution totaling more than $1.7 billion, as well as civil money penalties totaling more than $142 million.
- Definition of UDAP and UDAAP, including examples of the standards for unfair, deceptive, and abusive acts or practices
- What should the board know about the CFPB complaint process? What do employees need to know about UDAAP and handling complaints? How should complaints be tracked and evaluated?
Susan Costonis, Compliance Consulting and Training for FIs