Bankers and regulators are buzzing about UDAAP, that is: “Unfair, Deceptive, Abusive Acts and Practices.” “Unfair” and “deceptive” have been part of the banking lexicon for quite some time, but “abusive” is a new term and everyone is trying to figure out what it means.
Without clearly specified definitions, the application of the term abusive is entirely subjective. What is perfectly reasonable to one person might be considered abusive by another. Examiners are increasingly warning bankers to be careful about practices that could . . .
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