include training for any employees involved in credit transactions, regular monitoring, and compliance review of lending policies?
account for any perception of problematic or prohibited decisionmaking practices? •
• Do you communicate your policies and expectations for ECOA compliance to all your employees and have a process in place to review • fair lending policies to identify potential fair lending violations? • Do you have well-defined markup and compensa• tion policies? Do you have transparency to your lenders with access to these policies and procedures through the loan review process? • • Do you monitor pricing disparities so you can
practices are uncovered?
scrutiny by state or federal It may be challenging to regulators. Moreover, they will be better able to assure establish and manage lenders seeking reassurance compliance policies and that the contracts they’re Do you conduct regular procedures for monitoring purchasing won’t result in analyses of your loan practices in rate mark-ups, regulatory enforcement. pricing data for potential but recent action by the Chip Zyvoloski is a senior disparities on a prohibCFPB has made clear that it attorney for Walters Kluwer ited basis resulting from means business in ensuring Financial Services’ indirect your markup and that dealers provide fair lending business, which compensation policies? access to credit, and that monitors legislature that Do you conduct a regular indirect lenders are not affects the RV, auto, and absolved of responsibility if assessment of how you marine finance and dealer violations are uncovered. are positioning and markets. On Friday, Oct. 4, marketing credit products That means heightened he will present “ECOA pressure from your lenders to your customers? Compliance 101: What You about how well you adhere Do you have a defined Need to Know and Why You to the tenants of fair course of action to pursue Need to Care” from 7:45lending. corrective measures if 9:00 a.m. and “CFPB Dealers who take the discrepancies or dispariGuidance and Rate Markups” issue seriously and can ties are discovered within from 9:15-10:30 demonstrate ECOA compliyour dealership? ance to their lenders will be a.m. Contact What are your policies in a better position to defend him at Chip. Zyvoloski@ for compensating affected their business in case of WoltersKluwer.com. consumers if prohibited
VISIT US IN BOOTHS 337/447 & 618
2013 RV DEALERS INTERNATIONAL CONVENTION/EXPO
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