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
- Collection
- Credit reporting
- Payment
- Remittance
- Deposits
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
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 […]
Considerations for Managing an Offsite Review
They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]
National Compliance Officer Day
Today is National Compliance Officer Day, so TCA® wanted to share some recommendations from our compliance team with our fellow compliance professionals on potentially banking clients who may be engaged in activities relating to the cannabis industry. The challenge of providing banking services for industrial hemp and CBD Oil is that there are no current […]
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