Every bank is navigating the stormy seas of consumer compli-ance. New rules are raining down and a new consumer protection entity looms on the horizonrn(at this writing, pending financial reform will either create an agency or, at the very least, sharply heighten scrutiny by existing regulators). The biggest risk ahead, however, is barely a blip on most banks' sensors, despite being huge, close, and coming fast.rnA new focus on "unfair and deceptive acts and practices"-UDAP-is about to transform bank risk. Most of the industry hasn't yet spotted it, since examiners rarely raise concerns and enforcement cases are few. This issue, nevertheless, will soon be one of the toughest compliance challenges banks have ever faced.
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