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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.
'EXPLORING MBL WITH SBA GUARANTEES'
updated 03/02/15 01:31 PM
Free SBA and NCUA Event
Credit unions interested in getting into member business lending (MBL) are advised to attend the free “Exploring Member Business Loans with SBA Guarantees” training forum in Glendale on March 10.
HMDA/LAR REPORTS COMING DUE
updated 02/23/15 03:44 PM
Plus, SBL Resource Center
Credit unions subject to Home Mortgage Disclosure Act (HMDA) requirements for 2014 activity are reminded to submit Loan/Application Register (LAR) data to the Federal Reserve Bank processing center by the March 2, 2015 deadline.