Ensuring that your compliance program conforms to UDAAP’s latest requirements.
We conduct top-to-bottom UDAAP reviews to ensure your controls, procedures, and policies protect your customers against abuse, discrimination, and injury.
When there’s a change in compliance focus or exam procedures, the hope is that it brings greater clarity about your obligations and the way forward.
Often, however, it makes things murkier or demands greater introspection on your part.
For example, recent changes by the Consumer Financial Protection Bureau raise the bar on scrutinizing discriminatory practices. The move should compel banks to take a close look at every product and service through the lens of anti-discrimination standards.
Still, sometimes you need an analytical eye and outside advice to recognize the nuances in language and behavior that could be construed as abusive, misleading, or injurious to consumers.
We bring that critical thinking and evaluate your UDAAP compliance and show you how to adapt to the heightened scrutiny examiners apply during their reviews.
The TCA team examines your controls, procedures, and policies to root out and correct any weaknesses in your approach, paying particular attention to areas of focus for examiners. They include:
- Credit servicing
- Credit reporting
In addition, we
- Measure the effectiveness of your method of gathering, monitoring, and managing consumer complaints.
- Help staff understand their UDAAP obligations.
- Ensure that everyone – from BOD members to tellers – has proper training and understands what discriminatory, abusive, deceptive, and injurious practices mean in the context of their jobs and day-to-day work.
- Convey specific requirements to all your business units so they can make appropriate adjustments and adhere to the latest requirements.
We’re here to make sure that you’re not inadvertently violating the law, you’re addressing UDAAP risks across all your business lines, and protecting your bank from enforcement actions and reputational harm.
TCA designs A Better Way to Understand and Manage your UDAAP risk.
Key deliverables include:
- Assessing the quality of your internal controls and policies and procedures for UDAAP adherence
- Identifying your risk of violating UDAAP and establishing precautions to mitigate that risk
- Reviewing marketing materials, including print and digital ads, social media posts, and telemarketing scripts for UDAAP concerns
- Advising on UDAAP training, education materials, and procedures for bank staff to follow
Additional Compliance Topics
FDIC Insurance – Communication is Key
Because of the recent Bank failures, your customers may feel skittish today. Although the news pundits all are saying deposit accounts are insured up to $250,000, we know this may not be the case. Consider having Management craft a statement message or online banking alert assuring customers their funds are insured. You should also ensure …
FDIC Name Change – Updated
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance …
HMDA News and Census Tract Updates
Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated …
CRA Asset-size Thresholds Announced for 2023
The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. …
HMDA and HPML Thresholds Bumped Up for 2023
On December 28, 2022, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price …
New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections
Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase …
New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections Read More »