Star Social Media | UDAPP: it’s what the customer understands.


Posted by Jeff in Marketing

UDAPP: it’s what the customer understands.

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The Free Library. (2014). Retrieved Jun 26 2014 from’s+what+the+customer+understands.-a0308885159


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)??


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]


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