About This Course:
Our topic for the webinar will UDAAP -Unfair, Deceptive and (thanks to Dodd-Frank) Abusive Acts and practices. If your financial institution offers loans or deposit accounts, you need to have a
game plan for the revised UDAAP standards. Don't be fooled that UDAP is a simply a "big bank" problem, even though the CFPB announced large dollar settlements last year. Since 2008, 43% of UDAP violations cited by the FDIC were for banks with total assets of
$250 million or less. These violations can cause down-graded consumer compliance ratings, restitution, and CMP's. An FDIC supervised community bank in Indiana was surprised by an
$82,500 UDAP fine for
Reg E claims. What did they do wrong? How does it compare to
your Reg E investigation procedures? Financial institutions should also pay attention to
THIRD PARTY services, for example, Reward Checking programs. A community bank was cited for UDAAP penalties for claiming to give credit for 5 items per month. The bank failed to specify that the items had to have been posted in each monthly cycle. The restitution was NOT made public, but a reliable source estimated that
it exceeded $1 million dollars!There have also been "big bank" actions. The Consumer Financial Protection Bureau (CFPB) announced consent settlements with three major consumer financial services companies - Capital One Bank, Discover credit card company, and American Express Bank- over alleged deceptive and illegal practices involving add-on products for credit cards. These three actions alone, which took place from July to September 2012, resulted in restitution and refunds for consumers of $425 million, in addition to over $100 million in civil penalties paid to the Bureau and other agencies.
If you have customers, then this webinar is for you! Learn how Unfair or Deceptive or Abusive Acts or Practices (UDAP) could apply to your financial institution.
Covered Topics:- The definition of UDAP and UDAAP, including examples of the standards for "unfair", "deceptive" and "abusive" acts or practices
- Discussion of potential risks and recent UDAP court cases
- Learn five KEY points for UDAAP compliance to help avoid fines
- NEW-What do your "frontline" employees need to know about UDAAP and handling complaints?
- Managing Third Party Risks and UDAP
- Best practices to avoid UDAAP problems and learn how to handle complaints
- Helpful UDAP compliance resources and regulatory guidance, including FDIC Abusive Practices-Third Party Procedures
- BONUS- Attendees will receive a template for a Complaint Policy and Procedures in WORD that can be modified for your financial institution.
Who Should Attend
Compliance Officers, Risk Managers, Senior Management, Branch Managers, Call Center Managers, Loan & Deposit Operation Managers, Marketing staff, and Product Development specialists will find this session very beneficial.
The PresenterSusan Costonis is a compliance consultant and trainer. She specializes in compliance management along with deposit and lending regulatory training. Most of her 35-year career was spent as a banker in several areas including lending, marketing, compliance, and senior management. Susan has written numerous training manuals and successfully managed compliance programs and exams for institutions supervised by the OCC, FDIC, and Federal Reserve. She is a Certified Regulatory Compliance Manager, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states.