All in UDAAP

Example of a Deceptive UDAAP Violation

Example of a Deceptive UDAAP Violation

Adam Witmer
UDAAP

Adam uses this Compliance Clip (video) to provide an example of a “deceptive” UDAAP violation. The example in the video relates to television advertisements and Adam breaks down the three prongs that make this a definitive UDAAP violation example. Note: This video includes a transcript.

Lessons Learned from USAA - Reg E & UDAAP

Adam Witmer
Regulation E, Regulatory Update, UDAAP

On 1/2/19, new CFPB director Kathleen Kraninger signed a consent order with USAA Federal Savings Bank.  While the consent order outlines millions of dollars in restitutions and penalties, the order provides financial institutions with fairly detailed insights on a number of Regulation E violations identified by the Bureau.  As Regulation E applies to all financial institutions regardless of their regulator, this consent order can be used as a learning tool for appropriately complying with the Regulation.

Specifically, the USAA consent order outlined six main deficiencies that resulted in either a violation of Regulation or a UDAAP violation, or both, including…