Education & Events
CBC III: Unfair and Deceptive Acts or Abusive Practices/Advertising
“I have a question – I just saw an advertisement for a new product that our bank is offering, and I think this part of the ad…” Unfortunately, CBC members have had to make that kind of hotline call. We solicited suggestions regarding areas in which compliance officers were struggling. Advertising was on the list several times, and since a great many of the advertising questions might have a UDAAP component (usually driven by competitive issues), we are going to discuss these subjects together.
We will begin with a discussion of the actual UDAAP requirements, then move on to the requirements of Regulation DD (deposits) and Regulation Z (loans) regarding advertising. After completing that discussion, we will focus on real life applications – based on our company’s audit findings in various institutions, other resources, and our company’s experiences in this area. Be prepared to share opinions in a group setting.
Included in the discussion will be sample advertisements or radio scripts which may or may not contain regulatory or UDAAP issues – you will be the judge. And after all, that is part of the issue. The regulations are fairly clear, but UDAAP is in the eye of the beholder (think regulator or plaintiff’s attorney). We hope that this discussion helps you avoid issues with either group.
The subjects for the regulatory update will be determined by circumstances and releases from the various agencies.
Subjects as released by the CFPB and other federal agencies.
• Unfair Acts or Practices
• Deceptive Acts or Practices
• Abusive Acts or Practices
• Relationship to Other Laws
• Consumer Complaints
• A review of the appropriate sections of Regulation DD.
• A review of the appropriate sections of closed end Regulation Z.
Case Studies, Advertisements, Radio Scripts, Billboards
• A sampling of each – some will be fine, some wrong, some UDAAP – you be the judge
Subjects for future seminars will be shaped by regulatory events as they unfold. The CBC quarterly compliance program remains committed to providing as much up to the minute information as possible. The program will closely monitor releases from the CFPB and other agencies to assure that you have the most up to date and accurate information possible.
And for those who submitted topic suggestions that were not included in session so far in 2019, we are continuing to work through that list, and will attempt to incorporate as many of these suggestions as possible in future sessions. Fourth quarter of 2019 will be partially devoted to policies – what is required, etc. and their place in the overall compliance management system.
Bill Elliott, CRCM, Senior Consultant and Manager of Compliance
Bill Elliott has over 40 years of banking experience. As a compliance consultant and manager of the compliance division with Young & Associates, Inc., Bill works on a variety of compliance-related issues, including leading compliance seminars, conducting compliance reviews for all areas of compliance, conducting in-house training, and writing compliance articles and training materials. During his career, Bill spent 15 years as a compliance officer and CRA officer in a large community bank, and also worked for a large regional bank. He has been a lender for consumer, commercial, and mortgage loans, and has managed a variety of bank departments, including loan review, consumer/commercial loan processing, mortgage loan processing, loan administration, credit administration, collections, and commercial loan workout.
8:30 a.m. Registration & Continental Breakfast
9:00 a.m. Program Begins
12:00 p.m. Lunch (included)
1:00 p.m. Program Resumes
3:00 p.m. Program Adjourns
IBA Center for Professional Development
8425 Woodfield Crossing Blvd Suite 155E
Indianapolis, IN 46240
$350 IBA Member
$180 Each Additional IBA Member
100% Surcharge is applied for Non-Members.
WHO SHOULD ATTEND
Compliance Officers and Auditors should attend this session. In addition, all personnel with responsibilities for marketing and advertising will find this session useful, including senior management and others.
Elizabeth DeHaven, Education Coordinator
You will receive an e-mail confirmation at
Within three or more business days prior to the day of an educational program, no cancellation charge will be assessed. Within two days prior, 50% of the fee is assessed. Refunds are not provided for cancellations the day before or absences on the day of the program. Substitutions are welcome at