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CBC Q3 Community Bankers Association of Illinois (CBAI)

Second Quarter 2024 Community Bankers for Compliance Program UDAAP and Regulation X: Real Estate Settlement Procedures Act Main Subjects Understanding UDAAP Federal examiners often label any objectionable practices as violations under the UDAAP umbrella instead of revising the regulation. Unfortunately, far too often this creates “examiner discretion,” as the examiner can avoid a direct citation...

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