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#2202067 - 01/04/19 01:54 PM MLA and Indirect lending
totallyconfused Offline
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How is everyone handling the Statement of MAPR with Indirect loans. Are you using the telephone option or a signed Statement of MAPR?

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#2202150 - 01/07/19 02:49 PM Re: MLA and Indirect lending totallyconfused
totallyconfused Offline
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To follow up on this, the bank doesn't require VSI, GAP, Life/Disability Insurance on Indirect loans to MLA covered borrowers. But we have noticed that customers are being charged a $75 doc fee.

We think this doc fee falls into the category sometimes because it doesn't appear to be paying for the registration for vehicle.

Does anyone else think that the doc fee commonly charged falls into this category causing the loan to be an MLA covered loan?

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#2202822 - 01/12/19 07:47 PM Re: MLA and Indirect lending totallyconfused
Andy_Z Offline
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I think you need to know what this Doc Fee is for, and is it paid in cash sales? I'm not sure it can make a loan covered vs not covered, but it can influence your MAPR. I'd want more information.
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AndyZ CRCM
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#2208861 - 03/15/19 07:19 PM Re: MLA and Indirect lending Andy_Z
k8e Offline
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I have an indirect application that lists a $199 "Administrative Fee" that is added to the Cash Sales Price, and in bold under it, states, "An administrative fee is not an official fee and is not required by law but may be charged by a dealer. This administrative fee may result in a profit to dealer. No portion of this administrative fee is for the drafting, preparation, or completion of documents or the providing of legal advice. This notice is required by law."
If this type of fee is financed into the loan for a covered borrower, does it make it a covered transaction? Do we compute this amount in the MAPR calculation?
Last edited by k8e; 03/15/19 07:21 PM.
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#2209226 - 03/21/19 07:53 PM Re: MLA and Indirect lending totallyconfused
Andy_Z Offline
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That's tough because it isn't going to any specific item. Sounds like it is a fee a dealer can add to a sales price to increase profits, while still selling the car for $199 more than it sounds to the buyer. I would be inclined to say its a cost for the car, but you must ask the dealer when/under what conditions they charge this?

Then I get into fair lending if it's discretionary.

If they impose it on everyone and all sales, sounds like it's markup and part of the sales price. Your state association may also be able to explain the purpose of the fee.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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