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Thursday, March 21, 2019

UDAAP Best Practices


QUESTION
Hi, my friends at LCG! I love your FAQs and we discuss them all the time. I am on a small compliance team at a regional mortgage lender. We have come to the conclusion that, although UDAAP has many prongs, there seems to be no single, coherent regulation devoted to it. So, we have been building our own policies and procedures for UDAAP.

We think there is one section in the UDAAP policy that is needed, though – a section devoted to Best Practices. What we want is a Best Practices section that can be a list of bullet points, which can be put onto one page and distributed throughout our company. I know this may be a lot to expect, but I hope you can help.

Can you provide a list of some Best Practices for UDAAP that would be both a training aid and a one-page hand-out?

Also, we are now reviewing our policies and procedures, so please send me a link where I can contact you for help in drafting them. We will contact you soon.

Again, thanks for your dedication to mortgage compliance!

ANSWER
When I get an inquiry like this one, I feel very grateful to the mortgage community for recognizing our commitment to safe and reliable compliance. We get emails from readers from all over the country and many express their support for what we offer in our subscriptions. Thank you for subscribing!

Regarding your interest in having us draft or assist in drafting your policies and procedures, please contact us at compliance@lenderscompliancegroup.com.

Although you are correct in the challenge of providing a set of bullet points for Unfair, Deceptive, or Abusive Acts or Practices ("UDAAP"), I do think it is certainly possible to provide a core list of Best Practices to be used in the context of a training aid or a hand-out. In fact, we do have some guidance from various agencies, such as the Federal Reserve Board and the FDIC, among others.

In my view, a list of twelve bullet points on Best Practices for UDAAP can be set forth to address some areas with the greatest potential for unfair, deceptive, or abusive acts or practices. While the list would not be comprehensive, it certainly would be suggestive of a policy section as well as useful as a training aid and a hand-out to employees of a financial institution.

Here is a list of possible Best Practices relating to UDAAP:

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