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Happy Tin-niversary UDAAP!

Jul 13, 2020
By: Kristen L. Eustis
Financial Institutions

The year 2020 will be looked back at by many as a year of strife, and many of us are looking forward to 2020 coming to an end — especially the chance for a fresh start. While life may not get back to the “normal” we were accustomed to, most people are just looking to get back to some form of normalcy. 

The banking world had to adapt on the fly to the chaos that is the year 2020. Customers were being laid off or furloughed from their jobs. Businesses were being forced to close down for an unknown period of time. Financial institutions had to find ways to adapt to help their customers all while figuring out ways to help their own business and employees. 

Overnight, you became Small Business Administration (SBA) lenders, counselors, and dipped your toes into new technology. Did your check hold policy change? Have you stopped monitoring for excessive transactions? Did you have to adapt your underwriting standards? Did you start sending documents electronically?

Now that your customer base is starting to adapt to their new normal, we recommend that you take a moment and look at what changed and decide what your new normal is going to look like. This may involve more offsite employees, shortened banking hours, new ways to work with customers that does not involve face-to-face interactions. The industry will inevitably change. While you adapt to the changes, it would be a good idea to ensure your new normal doesn’t inadvertently create UDAAP (Unfair, Deceptive and Abusive Acts or Practices) concerns.

This is the 10-year anniversary of the Dodd Frank Act that gave us UDAAP. The tenth year is also known as the tin anniversary – which seems rather fitting. Tin is a metal that is strong and resilient. Strong and resilient also seems to aptly describes our industry. We survived the Great Depression, the Great Recession and we will survive the Great Pandemic. 

Reach out to a Wipfli relationship executive to mitigate any UDAAP or COVID-19-related concerns you may have for your financial institution – we are here to help you remain resilient, just like tin!


Kristen L. Eustis, CRCM
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