Payments, Deposits & UDAAP Compliance Consulting

Fee and disclosure risk in deposit products and payment services is where consumer protection issues turn into enforcement exposure fast. The CFPB and federal banking agencies have made overdraft/NSF practices, fee transparency, and UDAAP risk in consumer-facing products a sustained enforcement priority.

Arq Advisory assesses deposit and payments compliance programs with the same lens used in federal examinations — because our founder led those examinations as a CFPB Senior Commissioned Examiner.

Arq assesses UDAAP risk across consumer-facing products and practices, with particular focus on fee-related disclosures, marketing representations, and customer-facing processes. We evaluate whether products operate as represented, whether fee structures are transparent and fairly applied, and whether institutions have adequate UDAAP monitoring and governance in place. Our assessments cover the full UDAAP spectrum — unfairness, deception, and abusive acts or practices.

We evaluate overdraft and non-sufficient funds fee programs for regulatory risk, including fee disclosure clarity, opt-in and consent practices, transaction posting order implications, and representment fee practices. This area remains under intensive regulatory scrutiny, and Arq helps institutions identify exposure before it becomes a supervisory issue or enforcement action.

Arq evaluates complaint management and issue management programs end-to-end — intake, categorization, root cause analysis, escalation, and closure. We assess whether institutions are capturing consumer concerns early, converting complaints into measurable corrective action, and maintaining documentation that demonstrates responsiveness to regulators. Effective complaint and issue management is a core CMS expectation and a critical indicator of consumer protection commitment.

We review fee pricing governance structures to ensure fee schedules, disclosures, and actual practices are aligned. Misalignment between disclosed terms and operational practices is one of the most common UDAAP findings in deposit examinations. Arq identifies these gaps and recommends corrective measures.

Arq Advisory works with banks, credit unions, fintech companies, and payment service providers on deposit, payments, and UDAAP compliance.