UDAP / UDAAP: Spot the Issues

Recorded: August 6, 2025
Presented by: Kylee Durbin, CRCM, Manager, Forvis Mazars, LLP.

A three-hour seminar providing a comprehensive look at the rules governing unfair, deceptive and abusive acts and practices.

We will shed light on what UDAP/UDAAP (collectively “UDAAP”) actually means and how to look for it. This seminar will also include a test-your-knowledge workshop where you will review scenarios to see how to identify UDAAP concerns.

Despite regulations identifying what is an unfair, deceptive or abusive act or practice, UDAAP issues are highly subjective in nature. It is not just a consumer regulation; UDAP applies to both consumer and commercial customers. It does not apply solely to advertisements; it applies to disclosures, scripts, policies, procedures, acts and practices.

We will look at the definitions provided under Section 5 of the Federal Trade Commission Act as well as Sections 1031 and 1036 of the Dodd-Frank Statute what they mean to your institution as well as the FTC and CFPB policy statements on UDAAP. Throughout, we will identify key considerations to identifying UDAAP issues and concerns, particularly when you comply with other regulatory requirements but may still have a potential UDAAP in advertisements and disclosures. This seminar will highlight key UDAAP consent orders and takeaways you should be addressing in your compliance management program.

There will be dedicated time to test-your-knowledge where attendees will perform analysis on examples to identify UDAAP issues.

Here is what you will Learn:

• UDAAP Regulations/Guidance
  • Section 5 of the FTC Act
  • Dodd Frank
  • CFPB Bulletin
  • CFPB Policy Statement on Abusive
  • FTC Policy Statement on Unfairness
  • FTC Policy Statement on Deception

• Unfair
  • Definition
  • Key Considerations to identifying issues
  • Consent orders

• Deceptive
  • Definition
  • Key Considerations to identifying issues
  • Consent orders

• Abusive
  • Definitions
  • Key Considerations to identifying issues
  • Consent orders

• When you comply with a regulation but still may have a UDAAP
  • Spot the Issues