OCC Updates its UDAAP Booklet of the Comptroller’s Handbook

Adam Witmer
Regulatory Update, UDAAP

On December 3, 2024, the OCC issued version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” booklet of the Comptroller’s Handbook. The “UDAP/UDAAP” booklet applies to the OCC’s supervision of community banks.

The “UDAP/UDAAP” booklet informs examiners about the risks of banks and their third parties engaging in lending, marketing, or other practices that may constitute UDAP or UDAAP. The updated booklet:

  • Provides further clarity regarding sound risk management practices and guidance to examiners regarding overdraft services;

  • Incorporates updates from the Consumer Financial Protection Bureau regarding data protection and information security;

  • Includes an updated version of the “Appendix B: UDAP and UDAAP Risk Indicators;”

  • Reflects OCC and interagency issuances that have been published or rescinded since June 2020; and

  • Includes other minor updates for general clarity.

Read the OCC’s bulletin here.

The updated booklet can be found here.

Adam Witmer
Regulatory Update, UDAAP
Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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