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#2248023 - 01/22/21 05:00 PM Ancillary Products or Front/Back End Adds
TeamComply Offline
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Joined: Aug 2016
Posts: 540
For indirect lending purposes are ancillary products or front and back end adds defined anywhere? I know MLA address ancillary products, are there any other regulations that define/address these products? Thanks.

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Lending Compliance
#2248058 - 01/23/21 01:07 AM Re: Ancillary Products or Front/Back End Adds TeamComply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
We probably need more context to your question. What are your concerns?
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#2248109 - 01/25/21 07:11 PM Re: Ancillary Products or Front/Back End Adds rlcarey
TeamComply Offline
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Joined: Aug 2016
Posts: 540
For indirect lending - would it be appropriate to state that all front-end adds are non-cancellable and back-end adds are those that are cancellable?

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#2248112 - 01/25/21 07:26 PM Re: Ancillary Products or Front/Back End Adds TeamComply
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 919
USA
What type of credit product? When the CFPB was looking at ancillary products in indirect auto lending, they looked at extended warranties, GAP insurance (both GAP waivers and GAP waiver insurance), credit life, credit disability, involuntary unemployment insurance, and credit property insurance. In their credit card work, the CFPB looked at identity theft protection, credit monitoring, credit life, credit disability, and credit unemployment.
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