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:
