I have done a quick review of the UDAAP information that Jack provided to us in the last webinar and I am really struggling with the best option of how to complete procedures. On the one hand, it would be great to have them broken down by product/service; however, I think this would be a monster procedure for our bank if that were to happen. It may make more sense in our case to break it down by department but then I am concerned that I will overlook something. Anyone else have any thoughts? We do not have a policy or procedure currently in place for UDAAP and this is going to be on my radar for the first quarter of 2012.
I think tackling UDAAP by department makes sense. Many banks have implemented UDAAP checklists for product development and marketing as part of their procedure. Through these channels is where your major contact with consumers occurs and it reaches products/marketing for all departments. Then you could work your way through other departments (i.e. electronic banking, lending, retail deposit, etc.) and the products they offer making sure your current procedures/products aren’t unfair, deceptive or abusive to customers.
If you haven’t done so already, you should consider training for staff, especially those who create policies and procedures, develop products and work in the marketing department.