I am writing an UDAP Policy. Question #1: Should I include the extra "A" for abusive acts or practices? Question #2: Can UDAP apply to commercial customers?

Q2: UDAP applies to consumer credit contracts. The reg defines consumer as a 'natural person' who seeks or requires good, services or money for personal, family or household use other than for the purchase of real property. I take this to mean that it deos not apply to commercial customers.

I know that is straight from Reg. AA. Are there any gaps between section 5(a) of the FTC's Act and Reg. AA?

Please see this great document that is the first thing to come up when you type "UDAAP" into Google. It looks like it was put together by Lucy Griffin, based on the link name: http://www.floridabankersassociation.com...20-%20UDAAP.pdf

There is no way I'd limit my thinking around UDAAP to consumers only. It encompasses ECOA and fair lending - not solely consumer issues.

Just sat in on a really good webinar from Treliant, and it was specifically mentioned that banks have been hit (in one case, hit HARD) on UDAP issues that affected business customers.

BOL has one on Sept 28th also:

http://calendar.bollearningconnect.com/main.php?view=event&eventid=1314720455288

UDAP is not just for consumers anymore and is not limited to those issues addressed in Reg. AA.

Thanks for all the good information. Do you know of any articles or FILs that talk about UDAP for commercial customers?