Insights
The New “A” in UDAAP, Privacy, Third Party Relationships, and Marketing
By
Andy Lorentz
10.19.12
On October 12, 2012, DWT partner Andy Lorentz, along with Green Dot Corporation Chief Compliance Officer Christine Hunt-Fuhr and Bancorp Bank Senior Vice President, Director of Third Party Risk Branan Cooper, presented at ACI's 6th National Forum on Prepaid Card Compliance in San Francisco, CA.
The presentation was entitled "The New 'A' in UDAAP, Privacy, Third Party Relationships, and Marketing: Regulatory and Compliance Considerations for Prepaid Cards."
Objectives of the panel discussion included:
- Identifying the key regulators;
- Explaining the key points of regulatory guidance for third-party relationships;
- Summarizing the principles of unfairness, deception, and abuse in the context of offering and providing consumer financial products and services, including prepaid cards;
- Summarizing other key regulations that govern prepaid card marketing activities;
- Highlighting the risks of poor marketing practices;
- Highlighting industry best practices to mitigate risks related to marketing activities; and
- Providing examples from recent enforcement actions