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The State of UDAAP: Where Are We Now with All the Regulatory Changes?

The terms “UDAP” and “UDAAP” are perhaps the most significant ones ever to affect financial services compliance. That sounds pretty bold, but consider that the CFPB was given an almost-unlimited mandate under Dodd-Frank to “take any action…to prevent a covered person or service provider from committing or engaging in an unfair, deceptive, or abusive act or practice…”

OnDemand
Recorded Friday,
October 3rd, 2025
Presented by Carl Pry
2h total length
2.5 CRCM Credits
$299.00 or 1 Token

Includes: 30 Days OnDemand Playback, Presenter Materials and Handouts

  • Compliance
  • Lending
  • Lending Compliance
  • Management/Employee Development
  • Bank Legal Counsel
  • Board Member
  • Compliance Officer
  • Consumer Lender/Retail Banker
  • Risk Manager
  • Senior Management
  • Training Manager
  • Trainer

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Where are we now after the new administration and new leadership at the CFPB? Is UDAAP still a big deal? The short answer is yes – new bureau leadership has signaled one of their priorities is still enforcing consumer protection law that harms consumers, and UDAAP is at the center of that.

Institutions must be familiar with the standard means for compliance and the risk management process, as well as what is important today in this dynamic regulatory environment. Technical compliance is no longer the only issue to be concerned about, as UDAP/UDAAP can found even though every “normal” compliance requirement may have been strictly followed.

In this webinar, we’ll discuss understanding what examiners are focusing on, including areas where a clear rule or regulation might not even apply. This has been a major cultural shift in the regulatory function, and we’ll delve into how to identify UDAP/UDAAP, how to monitor and test for it, and where particular risks are found, among other topics.

What You'll Learn

  • UDAP vs. UDAAP: what does “abusive” really mean? Guidance and advice
  • The reach of UDAP/UDAAP: it isn’t only a CFPB issue – it affects ALL institutions, regardless of regulator
  • Scope of UDAAP: products, services, delivery channels, and methods
  • Examples of practices, as well as high-risk products and services: where should your focus be?
  • The concept of UDAAP Risk: how to handle it
  • The end of “Discrimination is UDAAP” (for now)
  • Emphasis on sales and marketing practices, and product management
  • Cultural change brought by UDAAP
  • Areas where you wouldn’t even think to look
  • Can treating a customer more favorably be unfair?
  • How to manage your UDAAP program
  • What are the regulatory expectations? Evaluations, risk assessments, more?
  • Going beyond the program: managing the culture of your organization

Who Should Attend

This session is ideal for compliance officers, auditors, management, counsel, marketing, sales, product development, business line management, and anyone else involved in any products, services, or practices that impact consumers because UDAAP is an issue that affects most everyone in the institution.

Carl Pry

Instructor Bio


Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Advisor for Asurity Advisors in Washington, DC. Through his more than 35-year working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves as the Chair of the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.


Continuing Education Credit Information

The State of UDAAP: Where Are We Now with All the Regulatory Changes? has been approved for 2.5 CRCM credits. This statement is not an endorsement of this program or its sponsor. Credits are redeemable for both Live and OnDemand viewing. For questions on certificates, please email support@oncourselearning.com. Certification holders must report these credits at https://aba.csod.com.

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