Objectives:

Upon completion of this course, participants will be able to:

• Interpret the legal definitions and standards for **Unfair, Deceptive, and Abusive** acts or practices.
• Differentiate between the three prongs of UDAAP and analyze real-world examples for each.
• Identify product features, marketing materials, and servicing practices that pose high UDAAP risk.
• Develop and implement a robust **UDAAP risk assessment** and monitoring framework.
• Analyze consumer complaints and feedback to proactively detect potential UDAAP violations.
• Apply UDAAP principles to emerging areas like **Digital Financial Services (DFS)**, FinTech, and Big Data utilization.
• Design clear, non-misleading, and compliant consumer disclosures, advertisements, and sales scripts.
• Understand the regulatory examination process and the expectations for UDAAP compliance documentation.

• Compliance Officers and Regulatory Affairs Managers
• Marketing and Advertising Specialists in Financial Institutions
• Product Development and Legal Counsel Teams
• Customer Service and Collections Personnel
• Internal Auditors and Operational Risk Managers
• Training and Quality Assurance Staff
• FinTech Executives and Compliance Leads
• Regulators focused on Market Conduct Supervision

• Case Studies analyzing major UDAAP enforcement actions across product lines.
• Group Activities involving identifying and mitigating UDAAP risk in marketing copy and loan documents.
• Discussions on the ethical line between aggressive marketing and deception.
• Individual Exercises on performing a UDAAP risk scoring for a new product.
• Role-playing a customer complaint intake and resolution process.
• Review of regulatory guidance and "no-action" letters.

Unit 1: The Legal Mandate of UDAAP

• The legal standard for an **Unfair Act or Practice** (substantial injury, not reasonably avoidable).
• Defining a **Deceptive Act or Practice** (material misrepresentation or omission).
• Interpreting an **Abusive Act or Practice** (taking unreasonable advantage).
• Illustrative examples of acts falling under each UDAAP category.

• Applicability of UDAAP across the full product lifecycle (origination to servicing).
• Regulatory guidance and bulletins on common UDAAP pitfalls.
• The role of the consumer's reasonable understanding in UDAAP analysis.
• Distinction between UDAAP and other consumer protection laws.

Unit 2: UDAAP Risk across the Product Life Cycle

• Avoiding deceptive advertising, including "bait and switch" tactics.
• Reviewing disclosures for clarity, accuracy, and timely delivery.
• Managing sales scripts and training to prevent misrepresentation.
• Risks associated with upselling, cross-selling, and add-on products.

• UDAAP risks in late fees, servicing transfer, and escrow management.
• Abusive practices in debt collection and borrower communication.
• Fair and transparent handling of payment allocation and account statements.
• Practices related to loan modifications, forbearance, and default.

Unit 3: UDAAP Compliance Management and Monitoring

• Integrating UDAAP controls into the overall Compliance Management System.
• Conducting a high-quality **UDAAP Risk Assessment** by business line.
• Developing policies, procedures, and internal controls specific to UDAAP.
• The importance of periodic, independent compliance testing.

• Establishing a robust system for capturing, tracking, and analyzing consumer complaints.
• Using complaint data as an early warning signal for potential UDAAP issues.
• Root cause analysis (RCA) of recurring complaints related to unfairness or deception.
• Reporting UDAAP risk metrics to senior management and the Board.

Unit 4: UDAAP in a Digital Environment

• UDAAP risks in algorithmic pricing, credit decisions, and "nudge" techniques.
• Ensuring transparency and fairness in digital disclosures and click-wrap agreements.
• Risks related to data usage, privacy, and non-transparent data monetization.
• Platform design and user interface (UI/UX) as potential UDAAP triggers.

Unit 5: Regulatory Enforcement and Remediation

• Navigating a **UDAAP-focused examination** and responding to findings.
• Understanding the potential penalties, fines, and consumer remediation requirements.
• Developing effective **remediation plans** and ensuring consumer restitution.
• Analysis of significant UDAAP enforcement actions and best practice takeaways.