B2B: UDAAP | Compliance Alliance

True or False:The Dodd-Frank Act explicitly defines “deceptive” within its UDAAP provisions.

True

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False

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Which of the following is *not* one of the three UDAAP elements?

Unfair

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B. Deceptive

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C. Exploitative

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D. Abusive

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Under the “unfair” prong of UDAAP, all of the following must be met *except*:

A. The practice causes or is likely to cause substantial consumer injury

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B. The injury is not reasonably avoidable by consumers

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C. The practice benefits competitors more than consumers

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D. The injury is not outweighed by countervailing benefits

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Which agency is the primary enforcer of the “abusive” standard?

A. Federal Trade Commission (FTC)

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B. Consumer Financial Protection Bureau (CFPB)

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C. Federal Deposit Insurance Corporation (FDIC)

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D. Securities and Exchange Commission (SEC)

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True or False:

State Attorneys General may enforce UDAAP provisions in federal court under Dodd-Frank § 1042.

A. True

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B. False

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Which emerging UDAAP risk area focuses on ensuring material terms are clear and conspicuous across digital channels?

A. Compliance Monitoring Systems

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B. Third-Party & Vendor Oversight

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C. Disclosure & Transparency

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D. Evolving Fee Models

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In monitoring UDAAP risks, institutions are advised to embed criteria into:

A. Quarterly earnings reports

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B. Real-time dashboards and exception-reporting systems

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C. Annual auditors’ conference presentations

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D. Corporate social responsibility statements

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All of the following are recommended disclosure best practices *except*:

A. Multi-channel delivery (email, app, mail)

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B. Plain-language formatting and call-outs

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C. Providing key terms in hyperlinks to reduce clutter

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D. Periodic user-experience testing with real customers

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Which institutional strategy helps detect hidden UDAAP issues through direct consumer feedback?

A. Risk-assessment memos

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B. Complaint data analysis

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C. Board committee formation

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D. Interagency guidance reviews

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When working with third-party vendors, institutions should __ to mitigate UDAAP risk:

A. Rely solely on the vendor’s own compliance

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B. Require UDAAP compliance clauses in contracts and ongoing monitoring

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C. Delay oversight until after a compliance exam

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D. Exclude fintech and payment vendors from reviews

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