UDAAP Reviews

This assessment will include observations, interviews, and reviews of internal documents and transaction files. The purpose of this assessment is to evaluate the Client’s risk associated with UDAAP principals, including compliance, credit, operational, strategic, and reputation, including review the following:
  • Marketing programs, advertisements, and other promotional material including printed and electronic ads, call scripts, and recorded calls for telemarketing and collections.
  • Policies, processes, and reports including internal risk assessments, organizational charts, and process flow charts.
  • Agreements with affiliates and third parties that interact with consumers on behalf of the entity.
  • Documentation regarding the use of models, algorithms, and decision-making processes used in connection with consumer financial products and services.
  • Complaint logs, internal controls, policies and procedures for avoiding unfair, deceptive, abusive acts or practices.
  • Training materials and ongoing training records for employees.
  • Sampling of products and services including descriptions, fee structures, disclosures, notice, agreements and periodic and account statements.
  • Loss mitigation practices with sampling of obligations in various stages of delinquency
  • Compensation arrangements, including incentive programs for employees and third parties, and
  • Documentation related to new product development.