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#2093320 - 08/15/16 07:36 PM Indirect Loans: Joint Intent
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
While reviewing monthly denials and sample of loan reviews both--I am noticing on apps for indirect loans from dealers there is rarely any indication the applicants would like to apply for joint intent.

Our LOs typically receive the faxed app & cb, review and approve, deny, or counter. Seldom speaking to the customer, even if it closes.

Is this on us as the lender even though the dealers take responsibility for taking the application etc.? If so, what is your suggestion to remedy this? New to this role and FI--I don't have any experience with indirect lending...so I'm unsure of where to begin to even look for the answer!

Thanks in advance.

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Lending Compliance
#2093323 - 08/15/16 07:43 PM Re: Indirect Loans: Joint Intent ScoutLaRue
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,439
Florida
Scout, you asked a lot of questions in one paragraph. One HUGE issue is with Fair Lending.

There should be a contract between the auto dealers and the bank spelling out who is responsible for what. It should be a bank contract approved by the bank's attorney. For the fair lending piece, since you are "unsure of where to begin" the FRB had a webinar on Indirect Lending in August 2013, and the information is still valid. You can see the webimar: https://consumercomplianceoutlook.org/outlook-live/2013/indirect-auto-lending/

Remember, auto dealers are pros and you need one on your side to stay ahead of them.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

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#2093408 - 08/16/16 01:47 PM Re: Indirect Loans: Joint Intent ScoutLaRue
ScoutLaRue Offline
Member
Joined: Jul 2016
Posts: 73
Thank you Rocky. I will see about reviewing those contracts. Appreciate the link as well.

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