ThiS FiEld guidE previously covered taming the elusive Unfair,
Deceptive and Abusive Acts or Practices (UDAAP) beast through risk assessment
(May/June 2013, page 10). Your intrepid explorers explained how to observe the
beast in its natural habitat to determine your inherent risk then to lay traps to
catch it in the form of controls. The next part of our quest takes us further into
the tangled jungle: Determining how well your traps have worked at taming
the beast. But beware: This journey is not for the faint of heart! It will take you
to areas of your bank that have rarely been traversed by compliance officers.
So don your pith helmet, grab your compliance survival guide, and ready your
flashlight to illuminate these mysterious spaces!
The journey’s most logical path forward goes through the product life cycle. From
concept to product initiation through customer service and termination, there
are many aspects compliance officers should examine to ensure that customers
are being treated fairly and receiving the product they believe you offered them.
And, although we are viewing our quest through the life-cycle lens, all testing and
monitoring should include both new and existing products, especially those that
have undergone changes.
BY meg sczYrBa, crcm, and
phillip r. “rick” Freer, Jr., crcm
A Field Guide to Taming
the UDAAP Beast
Adventures
Part II: MONITORING
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