The Free Library. (2014). Retrieved Jun 26 2014 from http://www.thefreelibrary.com/UDAPP%3a+it’s+what+the+customer+understands.-a0308885159
YOUR COMPLIANCE OFFICER HAS NO DOUBT BEEN TELLING YOU all about
Unfair, Deceptive de·cep·tive?
Deceptive or tending to deceive.
de·ceptive·ness n. . Abusive Tending to deceive. Practicing abuse. Prone to ill-treat by coarse, insulting words or harmful acts. Using ill treatment. Injurious, improper, hurtful, offensive, reproachful. ?Acts or Practices. UDAAP. It’s
probably starting to sound like a broken record. To marketing
professionals it sounds pretty straightforward: Don’t say anything
that’s not true (that'd be unfair), distort the truth
(deceptive). Suggest that customers do something against their
interests (abusive). In other words Adv. 1. in other words –. Otherwise stated. “in other words, we're broke”
put differently , just be straightforward when
disclosing information in an ad. As long as the proper information is
there, it shouldn’t be a problem.
Well, yes and no. For certain, requirements imposed by existing
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regulations such as Truth in Lending, Truth in Savings and the Fair
Housing Act, among others, are being enforced as never before. Missing
information under these rules (required disclosures, the Equal Housing
Lending logo, etc.) will be found by examiners just about every time and
criticized. But UDAAP goes beyond existing requirements.
One of the primary principles of UDAAP is consumers should've all
necessary information at their disposal in order to make an educated
decision regarding whether a financial product or service is right for
their needs. Marketing and advertising materials, whether in written
form, electronic, content of sales scripts and so forth, must fairly and
accurately represent the benefits, risks. Costs of products and
services. What we’re seeing now, however, is an evolution of this
mandate: It’s just as important how you present this information as
that you present it.
Appearances matter. They always did, of course. No more so than
now. What should you be conscious of?
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* Don’t bury important information in the small print. A
classic defense of unfair marketing practices has been, “We did
disclose everything according to according to
1. As stated or indicated by. On the authority of: according to historians.
2. In keeping with: according to instructions.
3. ?the rules. It’s not our fault the
person didn’t read everything.”. Even though there are type
size requirements in very few rules, there is a line of thought Out
there that including multiple lines of 4-point type at the bottom of an
ad tells the reader “no need to read this, it’s not really
important.”. If it’s information critical to whether or not a
consumer decides it’s a suitable product, it shouldn’t be
buried in the small print. Consider making it more obvious. Thus in
UDAAP parlance Parlance –. A concurrent language.
[“Parallel Processing Structures: Languages, Schedules. Performance Results”, P.F. Reynolds, PhD Thesis, UT Austin 1979]. , less deceptive.
* Watch what you’re emphasizing. As the title here suggests,
it’s not what you say hut what the customer understands. If the
overall impression of your message glosses over information about fees
or product restrictions, take a second look. This isn’t fun, since
it means making information that's less “customer-friendly ”
more prominent. In fact, it should stand out almost as much as
information that attracts the customer to the product in the first
place. In any case, make sure it’s not easy to overlook.
* Take a look at your advertising copy in this light. Think of
yourself not only as a marketer. A consumer advocate. Does the offer
seem to be too good to be true? If so, find what you’re pushing to
the background and make it more evident.
BY CARL G. PRY. CRCM CRCM Certified Regulatory Compliance Manager (American Bankers Association)
CRCM Canadian Regional Climate Model (University of Quebec, Montreal, Canada)??
ABOUT THE AUTHOR
CARL G. PRY, CRCM is a senior director for Treliant Risk Advisors
in Washington, D.C., where he advises clients on a wide variety of
compliance, fair lending, corporate treasury. Risk management
issues. Email: [email protected]