Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Manual

The Dodd-Frank Act not only mandates "fair, equitable and nondiscriminatory access to credit" for consumers, but also makes it illegal for mortgage brokers/lenders to engage in any unfair, deceptive or abusive acts or practices as it relates to the consumer. Rulemaking granted to the CFPB under Dodd-Frank, in conjunction with revisions to TILA, ensures that lenders and brokers are prohibited from engaging in what is considered to be abusive or unfair lending practices. This has resulted in multiple federal statutes compelling mortgage lenders and brokers to establish and adopt a UDAAP policy in order to comply with regulatory requirements and demonstrate a commitment to the CFPB's expectation of consumer transparency.

Overview

Looking for a resource to outline your company's approach to Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)? Look no further. The UDAAP Policy Manual provides an overview of the UDAAP requirements and the reasons mortgage brokers, lenders, and originators need a policy on this trending topic. Additionally, it outlines a comprehensive policy that meets the standards and expectations called for by the CFPB through Dodd-Frank. Finally, it provides support for compliance of existing federal regulations like TILA (which was amended by Dodd-Frank to address Mortgage Reform and Anti-Predatory Lending requirements within TILA).



Benefits

The policy features the following benefits:

  • Complete AllRegs' Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) Policy Manual, saving you development time and resources
  • A complete policy manual is delivered via email within one business day after purchase
  • Ability to add, delete and update your plan to suit the business model of your organization
  • Meet your regulatory or internal compliance requirements
  • Affordable one-time purchase fees

Optional Services

Maintenance: Receive regular and ongoing industry updates to keep your policy within regulatory requirements.

Publishing: Publish your manual, including your company procedures, in AllRegs Online to complete your policy manual solution.

Contact your account manager for information regarding these optional services!


Policy Manual
Unfair, Deceptive, or Abusive Acts or Practices (UDAAP)
Section Title Priority Action
1.1 Goals and Objectives Mandatory Review Include the point of view or culture of your organization in this section, if applicable.
1.2 Required Review Mandatory Review Be sure this accurately reflects your company’s annual policy review process.
2.1 Internal Controls Mandatory Review Include or reference related procedures in this section.
3 Staff and Training Mandatory Review Include the means by which your organization provides and tracks required training.
5.2 UDAAP Policy Implementation Recommended Best Practice This includes requirements for evaluating your procedures, documentation, disclosures, and customer interactions for potential risks related to UDAAP. Consider referring to your processes that support this requirement.
6.1 Best Practices Recommended Best Practice The risk assessment within this section requires the use of the CFPB template (22 pages) or a similar form. You should identify the forms to be used in advance of any implementation efforts.
6.5 Social Media Optional Enhancement Refer to related procedures and oversight protocols that are in place to support the use of Social Media.
6.6 Consumer Complaint Management Recommended Best Practice Modify or expand this to accurately reflect the complaint management program that is in place within the organization, and refer to your customer complaint policy.