The Board emphasizes that its examiners will completely review all aspects of a bank’s deposit advance program for conformity with relevant law (like the UDAP provisions of Section 5 regarding the FTC Act). In addition it tips to dangers due to making use of third-party contractors, particularly where fee-sharing or other plans create incentives for improper overuse of DAP loans. Read more “The Board’s Statement reflects a strategy distinct from compared to the Agencies into the DAP issue.”