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|January 28, 2015|
|TIPs Bulletin #15-04||2014 Residential Mortgage Loan Report|
|TIPs Bulletin #15-03||HMDA/LAR Reports|
|January 16, 2015|
|TIPs Bulletin #15-02||2015 Information Returns and Disclosures|
|January 15, 2015|
|TIPs Bulletin #15-01||Important Reminder: Limitation on Credit Card / Unsecured Open-end Credit Late Fees (CA Financial Code 4001)|
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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.
TILA-RESPA RULE CHANGES FINALIZED
updated 01/26/15 04:27 PM
Plus, FinCEN Issues New SAR Stats
Proposed amendments by the Consumer Financial Protection Bureau (CFPB) to the TILA-RESPA Integrated Disclosure rule were finalized in late January. These changes are effective Aug. 1, 2015.
ELECTRONIC DBO FILING
updated 01/16/15 04:35 PM
TIPs Bulletins; Cuban Asset Reg.
The Department of Business Oversight (DBO) has standardized electronic forms for weekly and quarterly reporting of local agency deposits and securities, allowing financial institutions to submit their weekly reports to the DBO electronically rather than through the U.S. mail. This change was made possible by Assembly Bill 2298, which took effect Jan. 1.