Glossary
What is UDAAP?
The three prongs
Unfair: causes or is likely to cause substantial injury that consumers cannot reasonably avoid and that is not outweighed by countervailing benefits. Deceptive: a representation or omission likely to mislead a reasonable consumer. Abusive: materially interferes with a consumer's ability to understand a term, or takes unreasonable advantage of a consumer.
Where UDAAP risk shows up in lending
Marketing claims, disclosures, servicing communications, collections, and fee practices are common UDAAP flashpoints. Inconsistent or unreviewable practices across cases are a frequent source of exposure.
How Hadrian reduces UDAAP exposure
By standardizing the case lifecycle and keeping a tamper-evident record of what was communicated and decided in each case, Hadrian makes practices consistent and reviewable — the opposite of the ad-hoc, hard-to-audit processes that create UDAAP risk.
FAQ
UDAAP — common questions
Who enforces UDAAP?
The CFPB enforces UDAAP under Dodd-Frank; the FTC enforces 'unfair or deceptive' acts under the FTC Act. State regulators have parallel authority.
What's the difference between UDAP and UDAAP?
UDAP (FTC Act) covers unfair and deceptive practices; UDAAP (Dodd-Frank/CFPB) adds the 'abusive' prong.
The institution around the intelligence
See Hadrian run your case lifecycle — intake to close, every decision audited.
Governance-native case processing for lenders and regulated teams.