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|July 16, 2014|
|TIPs Bulletin #14-14||Canada’s Anti-SPAM Legislation (CASL) and Its Impact to U.S. Credit Unions|
|June 30, 2014|
|TIPs Bulletin #14-13||Voluntary Liquidation|
|TIPs Bulletin #14-12||Annual Indexing of HUD’s Basic Statutory Mortgage Limits for Multi-Family Housing Programs|
|June 10, 2014|
|TIPs Bulletin #14-11||Interim Rule - Exchange of Mutilated Paper Currency|
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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.
TIPs, FinCEN PUB, HANDBOOK UPDATE
updated 07/21/14 12:44 PM
The Latest in Compliance
A new TIPs Bulletins (Technical Information and Procedures) has been posted by the California and Nevada Credit Union Leagues on Canada’s anti-SPAM legislation, which went into effect July 1 and is similar to the U.S. government’s CAN-SPAM Act of 2003.
CFPB ISSUES INTERPRETIVE RULING
updated 07/14/14 03:48 PM
'Ability to Repay' Discussed
The Consumer Financial Protection Bureau (CFPB) has issued an interpretive rule to clarify that when a borrower dies, the name of the borrower’s heir generally may be added to the mortgage without triggering the bureau’s Ability-to-Repay Rule.