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Omni Orlando Resort at ChampionsGate
1500 Masters Blvd
ChampionsGate, Florida 33896

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Thursday, May 10, 2012

2:50 PM - 3:35 PM
Track: Loyalty and the Customer Experience View Track

THE GROWING UDAAP RISK FOR REWARDS PROGRAMS

Mike Lamberth, VP, Compliance, CAPITAL ONE
Sarah Olthoff, Sr. Compliance Director, CAPITAL ONE
Megan Baynes, Compliance Manager, PNC BANK

Rewards programs have traditionally not posed significant compliance or reputation risks to institutions offering them.  However, rewards programs are emerging as a growing area of UDAAP and reputation risk.  Regulators, including the CFPB, have begun to look very closely at these programs, including how they are structured, what information is communicated to customers, how well they are operationally managed, and what value these product truly provide to a customer.  This session will include a discussion of evolving key risks of these programs, and we will share proactive strategies institutions can take to mitigate these emerging risks.

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