White Paper

CFPB Developments - What Does a Strong Fair Lending Compliance Program Look Like

 
What does a strong fair lending compliance program look like? The fair lending policy should be up-to-date, there needs to be fair lending training for both current and new officers and employees, monitoring of fair lending policies to make sure the program is in compliance with fair lending laws, additional monitoring of other policies that work in conjunction with fair lending policies to make sure everything is covered, a frequent review of policies to avoid or remedy any fair lending violations, loan data review for lending irregularities, assess any marketing used to promote loan products, and meaningful oversight of fair lending compliance.

Why should you do it? As an indirect auto lender, you are under the direct jurisdiction of the CFPB. You are not protected by the third-party creditor exception under Regulation B.

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Franklin Drake is a Partner in the law firm of Smith Debnam Narron Drake Saintsing & Myers. He focuses on creditor's rights, bankruptcy, and repossession law. Mr. Drake advised and represented most of the major secure and unsecured financers on secured lending, bankruptcy and regulatory compliance matters. He lectures regularly for various training courses, bankruptcy and regulatory compliance programs.

Faculty

Franklin Drake

Franklin Drake

Smith Debnam Narron Drake Saintsing & Myers, LLP