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Course description

 Everything old, is new again. In January 2020, the CFPB issued a policy statement on how it was interpreting and enforcing UDAAP. In March 2021 the new acting director of the CFPB announced a reversal of that position. We expect more reversals and more enforcement actions as the CFPB reverts to a position that enforcement actions are a demonstration of consumer protections. Expect a lot of action based on complaints, fair lending, and UDAAP.

The same day the SBA launched its Payment Protect Program for small business loans, the first class action suit was filed against a major bank because of its PPP loan procedures. The suit was filed before the first loan would be funded.  When there is any possible error, customers and attorneys are ready to tell you about it.

What must you prepare for? Paraphrased, here is what one circuit court said, “consumers are protected from a company’s deception, even if they never actually read its disclosures.” What you say must be accurate. What you do must be what you said.

Banks must be listening to customers and they must be treated fairly. There is no referring to the fine print. UDAAP has never been a bright line test type of law as there is subjectivity and the bank must understand that in the way it develops and delivers products and services. And this isn’t just on a new product like a PPP loan, but on your existing and sometimes “very mature” products. That is what penalties teach us.

Does your bank understand UDAAP/UDAP and the complaint process? We will look at UDAAP standards, complaint tracking and resolution and enforcement actions, to help you establish a process to avoids criticisms.

BONUS: Webinar participants will receive a Complaint and Inquiries Policy template as part of the course materials.


Andy Zavoina

Mr. Andy Zavoina, CRCM, is an Executive Vice President with the Glia Group, Inc., best known for its involvement with BankersOnline.com. He joined Glia and BOL in 2003. Mr. Zavoina has been in finance and banking for over 42 years. Over 20 years were with a two-bank holding company that had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He has done loan workouts, has been a consumer, commercial and real estate lender and managed those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks. Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He is a BankersOnline Guru. He also served on the Texas Bankers Association's Compliance Committee. He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers. He has written articles and lectured on compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace to local, state and national associations across the U.S. and teaches basic compliance and compliance management. You can reach Andy on the Internet by using his e-mail address, [email protected], or visiting http://www.bankersonline.com.

Course curriculum

  • 1


    • Access Webinar

  • 2


    • Slides

    • Materials

    • Questions and Answers