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|October 15, 2014|
|TIPs Bulletin #14-23||SB 1050—Notaries Public: Verification of Identity: New Boxed Notice Required|
|October 1, 2014|
|TIPs Bulletin #14-22||Assembly Bill 2293 – Mandates Baseline Insurance Requirements for Transportation Network Companies|
|TIPs Bulletin #14-21||California Unclaimed Property Holder Notice Reports Coming Due|
|TIPs Bulletin #14-20||Assembly Bill 2742 – Revised Model Language for California Consumer Caution and Home Ownership Counseling Notice|
|September 23, 2014|
|TIPs Bulletin #14-19||AB-1858 Change to Financing Statement|
|September 18, 2014|
|TIPs Bulletin #14-18||Reg Z and Reg M Exemption Threshold Adjustments|
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Internal Audit Services
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The CFPB is concerned with indirect auto lender markup and compensation policies with auto dealers, stating that the incentives these policies create and the discretion they permit cause significant risk for pricing disparities on a prohibited basis. An auto lender may be liable for such pricing disparities under the ECOA for both disparate treatment and disparate impact.
The CFPB Bulletin includes discussion on limiting fair lending risk in indirect auto lending, including:
Most credit unions are not subject to CFPB jurisdiction, and enforcement authority for ECOA and Regulation B violations lies with the National Credit Union Administration (NCUA) for federal credit unions and Federal Trade Commission (FTC) for state credit unions.
However, couple the CFPB Bulletin with NCUA’s recent Letter to Federal Credit Unions regarding fair lending exams, 13-FCU-02, and it's clear that credit unions should take note. If your credit union has a markup and compensation policy for indirect lending, please review the CFPB Bulletin for guidance.
Does your credit union have the resources to effectively monitor your indirect lending portfolio for possible ECOA violations and address the effects of dealer markup and compensation policies? Are changes needed to compensate dealers in a different way, such as a flat fee per transaction method? These are relevant questions to ask as you review the CFPB Bulletin.
NCUA’s Letter to Federal Credit Unions includes additional resources to review and ensure your credit union has a strong fair lending compliance program. These resources include a new NCUA Fair Lending Guide and a Fair Lending Webinar scheduled for April 4.
'NMLS' RENEWAL PERIOD BEGINS NOV. 1
updated 10/17/14 01:01 PM
Guidance for Mortgage Loan Originators
The Nationwide Mortgage License Servicing and Registry (NMLS) annual renewal period begins Nov. 1 and ends Dec. 31, where mortgage loan originator registrants must renew their registrations annually, according to federal regulations.
FED'S UPCOMING FAIR LENDING WEBINAR
updated 10/10/14 09:09 PM
Also, Unclaimed Property Workshop
The Federal Reserve Bank of San Francisco is holding a webinar on fair lending issues and hot topics, where representatives from seven federal agencies will discuss a variety of emerging fair lending issues and hot topics.