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Latest Compliance - Indirect Lending Topics

AA Notice Required if Counteroffer Not Accepted?

06/10/2013

I know that adverse action notices are required on indirect lending contracts we deny, but are Adverse Action notices required when we submit a counteroffer that is not accepted?

The Foxhunt

01/01/2000

The most recent fair lending development comes, not from the U.S. Department of Justice ("DOJ") but from a "friendly" regulator, the Board of Governors of the Federal Reserve System ("FRB").

Fair Lending, ECOA et al.

01/01/2000

Fair lending has reared its head more than once in the 1900's and promises to be a front burner topic in the coming decade. In the 1990's, fair lending enforcement has reached an all time high.

Indirect Lending

01/01/2000

The Foxdale case flags the importance of self-assessment. It is clearly not a time to use "see no evil" as a defense ploy.

Risks In Indirect Lending

07/01/1998

FDIC examiners found that some indirect lenders allowed car dealers to charge more to female purchasers than to male purchasers.

Question & Answer

07/01/1996

Question: My bank's indirect lending department wants to draft a "friendly" adverse action letter. They also want to preprint the ECOA notice on the back side of the stationary.

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Indirect Lending Applications

Question: I have a question regarding indirect lending applications. We require the dealerships to have the customer sign on the application form our institution provides.

Fair Lending: On the Front Burner

Fair lending enforcement is ramping up. Current enforcement efforts are breaking new ground with the consequence that lenders must manage fair lending programs to include these new horizons.

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CTR for Large Check for Christmas Bonuses

01/19/2020

A customer cashes a large check that results in a reportable CTR. My question is that the funds from the check are for Christmas bonuses for the customer's employees. I have the customer as the conductor, but who will be the beneficiary? Can we list the business as the beneficiary?

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