Representative Engagements

Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) and Debt Protection Products

Due to regulatory concerns related to UDAAP compliance, the bank requested CrossCheck assist with a multi-phased review of its administration of debt protection products including a look-back of thousands of customer loans with debt protection originated over several years. We provided a project manager and a team of a dozen consultants.The project manager assisted in developing the methodology to complete the review, trained the review team, provided management reporting, and maintained quality assurance throughout the project. Detailed analysis of each customer’s activity and loan servicing was performed over the life of the loan to identify situations that resulted in customer harm. Recommendations for customer remediation were provided to management. We also provided management with the information it needed to evaluate its practices, and take appropriate corrective action to mitigate any future risk and the potential for consumer harm.

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Client Type

Regional Bank – ($10 – $50 billion in assets)

Service Type

Compliance Consultation – Issue Remediation