Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices

Overview

The content in this booklet informs examiners about the risks of banks and their third parties engaging in lending, marketing, overdraft programs, or other practices that may constitute Unfair or Deceptive Acts or Practices (UDAP) or Unfair, Deceptive, or Abusive Acts or Practices (UDAAP). This booklet provides expanded procedures to assist examiners in evaluating UDAP and UDAAP risks and in assessing associated risk management (including evaluating a bank's Compliance Management Systems). This booklet is structured consistent with interagency consumer compliance rating system elements and provides information on other risks related to UDAP and UDAAP.

Applicability

This booklet applies to the OCC's supervision of national banks and federal savings associations. References to national banks in this booklet also generally apply to federal branches and agencies of foreign banking organizations. Refer to 12 USC 3102(b) and the "Federal Branches and Agencies Supervision" booklet of the Comptroller's Handbook for more information.