by M&M Consulting | Apr 7, 2023 | UDAAP
CFPB has published a policy statement on the Abusive standard “Extra A,” in UDAAP. Consumer Compliance professionals who’ve been practicing their art since 2010 likely remember the day that “extra A” helped UDAAP become famous. That “extra A” was for the new Abusive...
by M&M Consulting | Mar 20, 2023 | UDAAP
Imagine a consumer not being able to recalculate a fee on their monthly deposit account statement based on the information in the statement? It could happen, and it could be a UDAAP as well as a violation of Truth-In-Savings (TISA) Regulation DD. Assume Bank XYZ has a...
by M&M Consulting | Mar 17, 2023 | UDAAP
Reviewing For Potential Unfair, Deceptive, Abusive Acts and Practices (UDAAP) Issues: On March 8, 2023, the CFPB issued a special edition of their Supervisory Highlights publication to highlight issues noted at financial institutions and servicers regarding junk fees....
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