ABA Regulatory Compliance Conference
THE NEW "A" IN UDAAP: WHAT DOES THIS MEAN FOR YOUR COMPLIANCE PROGRAM?
Section 1031 of the Dodd-Frank Act "prohibiting Unfair, Deceptive or Abusive Acts or Practices adds an additional "A" to the FTC's definition of Unfair and Deceptive Acts and Practices. What would make a practice "abusive" in this new Dodd-Frank era? This session will explore all of the current issues surrounding UDAAP, including ATM fees, punitive loan provisions, credit life and yield spread premiums. While we have a separate session covering the new overdraft rules, this session will also touch on the new overdraft requirements as well. Additionally, we will use recent enforcement actions as case studies in new exam trends and explore the standards leading to enforcement actions (e.g., what is substantial injury?) as well.