New UDAAP Exam Parameters: Beyond Fair Lending

On-Demand Webinar:
StreamedJun 16, 2022Duration60 minutes
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Compliance alert!

The changes to the UDAAP exam manual go far beyond fair lending.  Under the new parameters, the CFPB can bring discrimination claims related to non-credit financial products and services.  You can’t afford to miss this crucial update.

  • Identify discriminatory acts or practices that materially increase the risk of consumers being treated unfairly
  • Recognize how discrimination impacts deposit accounts, marketing, fees, product offerings, and servicing activities
  • Update policies, procedures, and processes to avoid discrimination
  • Create procedures to respond to service and collections calls from consumers with limited English proficiency (LEP)
  • Develop a compliance program to monitor for potential Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) concerns, including discrimination
  • Provide examples of discriminatory practices during training exercises
  • Assimilate recent changes to the CFPB’s UDAAP examination manual


Recently the CFPB broadened the spectrum of what may qualify as a UDAAP violation and updated their examination manual accordingly.  The changes focus on identifying discrimination in all consumer finance markets, including deposits, payments, remittances, and collections.  It’s critical that financial institutions understand, and are monitoring for, practices that may trigger unfair discrimination throughout the organization, including the assessment of fees and level of service provided to accountholders.  In short, the exam manual and UDAAP compliance now go way beyond fair lending!

Denying any product or service, such as refusing to open a checking account based on a person’s religion or race, is an unfair practice, even when the Equal Credit Opportunity Act has not been violated.  For example, it’s likely that your institution uses demographics to aid in marketing products and services.  But these models and algorithms may inadvertently include a discriminatory practice, even when used for deposit-related activities.  Join this timely webinar to learn how to recognize potential UDAAP risks in all areas of your institution.


This informative session is designed for staff involved in developing, marketing, or monitoring financial products and services offered by your institution, including operations staff, deposit staff, marketing personnel, trainers, compliance staff, auditors, and risk management personnel.


  • Examples of discriminatory practices to aid in training exercises
  • Considerations for identifying LEP accountholders
  • Sample UDAAP policy
  • UDAAP risk assessment template
  • Reference list
  • Employee training log
  • Interactive quiz
  • PDF of slides and speaker’s contact info for follow-up questions
  • Attendance certificate provided to self-report CE credits

NOTE: All materials are subject to copyright. Transmission, retransmission, or republishing of any webinar to other institutions or those not employed by your agency is prohibited. Print materials may be copied for eligible participants only. 

Presented By

Molly StullMolly Stull
Brode Consulting Services, Inc.