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Course description

Technical compliance does not always protect against an allegation of a UDAAP violation. Unfortunately, penalties for violating the UDAAP provision can be drastic - up to $1 million per day for a knowing violation of the law. And language of the UDAAP provision is broad and vague.
The Truth in Savings Act (TISA) was passed to enable consumers to make informed decisions about accounts at depository institutions. This law requires banks to provide disclosures so that consumers can make meaningful comparisons among depository institutions.

This session will assist with detecting and avoiding potential UDAAP-related violations as related to consumer deposit account activity. We will identify acts or practices that increase the risk of UDAAP-related violations of TISA.

This session covers the rules applicable to: 

  • Initial and subsequent disclosures - Content vs. Actual Practices
  • Advertising - Matching to Disclosures and Actual Practice
  • Hyperbole - Superlatives can be a trap
  • Reward Programs and Add-ons - Identity Theft Protection, Insurance, etc.
  • Overdraft Programs (ODP)
  • Debit posting method
  • Board and Management Oversight
  • Formal Compliance Program
  • Response to Consumer Complaints
  • Compliance Audit


Partner, Cashman Compliance Solutions, LLC

Patricia Cashman

Patricia Cashman is a partner in Cashman Compliance Solutions, LLC. She is responsible for consumer compliance reviews, Bank Secrecy Act (BSA) and Anti-Money Laundering reviews, and compliance and BSA training. Patricia began her banking career in 1969. She has been the senior operations officer for three Dallas-Ft. Worth area community banks, an assistant examiner for the Texas Department of Banking and managed the compliance/internal audit division of TIB - The Independent BankersBank, one of the largest bankers' banks in the country. Additionally, Patricia has spoken as a webcast/teleconference presenter for the American Bankers Association (ABA), BankersOnline (BOL) and the Center for Financial Training (CFT), taught a variety of compliance subjects for the Texas Bankers Association (TBA) and ABA at their respective Compliance Schools. She also serves as a BOL GURU and been a speaker/trainer for numerous banks and compliance organizations.

Course curriculum

  • 1


    • UDAAP & Truth in Savings: 10 Common Errors

  • 2


    • Materials

    • Slides

    • Questions and Answers