Mar 10

Recent Compliance Issues: 2/7/14 – 2/20/14


1. Wells Fargo announced that it would continue dealer-reserve pricing in its indirect automobile lending operation. Such an approach is a ready-made fair lending red flag that has been in regulator’s cross hairs for some time.

Our staff has reviewed indirect lending programs at a variety of institutions and analyzed interest rate overages to ensure the absence of discriminatory pricing. We can help you implement a fair lending program that will assure your regulator that you are monitoring the pricing discretion you afford to the dealers in your network.

2. “Top CFPB Official Vows to Crack Down on Mortgage Servicers”, according to today’s (2/20/14) headlines.

  • Have you decided to retain mortgage servicing to better serve your loyal customer base?
  • Are your mortgage servicing policies and procedures in conformance with the new changes that became effective on January 10, 2014?

Sure, the CFPB is probably laser-focused on the mega-players in the mortgage servicing market, but don’t take any chances.

Let us review your mortgage servicing policies and procedures to make sure that you are ready for that next examination.