Can someone explain the difference between UDAP and UDAAP? I see the two acronyms used interchangeably in bank trainings, but I think there is a difference. Shouldn't it be one or the other?

I know the extra A in UDAAP stands for Abusive.
I know Reg AA was rescinded when CFPB became the authority on UDAP.

Our bank policies refer to UDAAP. Must I include "UDAP"?

Thanks in advance.

The underlying regulatory/legal authority. From the FDIC:

Supervisory resources pertaining to unfair, deceptive, or abusive acts or practices. This includes Unfair or Deceptive Acts or Practices (UDAP) under Section 5 of the Federal Trade Commission Act (FTC Act) as well as Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act).

https://www.fdic.gov/consumer-compliance/unfair-deceptive-or-abusive-acts-or-practices

We include both in our policies and procedures. We had shifted to UDAAP only, but the Federal Reserve complained.