MBA Reviews Exam Manual Changes Evaluating UDAAP

On March 16, the Consumer Financial Protection Bureau issued a press release announcing changes to its supervisory operations by publishing an updated exam manual for evaluating UDAAPs (Unfair, Deceptive, or Abusive Acts or Practices). The 2022 UDAAP module showing the new language is available for your review (password required), with the new language highlighted in yellow as compared to the 2012 version. Most of the new language focuses on how CFPB examiners are to examine for discriminatory bank practices that could be UDAAP violations. At this time, the Office of the Comptroller of the Currency, the Fed and the Federal Deposit Insurance Corporation have not issued similar updates to their exam manual UDAAP modules.