The Right Approach to Adverse Action Notices

Compliance expert gets into the weeds on adverse actions. He explains why you must send a notice to every affected customer, and breaks down your choice of processes.
Compliance expert gets into the weeds on adverse actions. He explains why you must send a notice to every affected customer, and breaks down your choice of processes.
The House Financial Services Committee’s decision to release confidential CFPB documents was a big win for the industry. But will it be enough to stop the bureau’s attack on dealer participation?
The American Financial Services Association is commissioning a study to address the CFPB’s concerns for discrimination related to rate participation programs. It will also provide a cost-benefit analysis of alternative dealer compensation models.
A New Jersey housing bias case the Supreme Court agreed to hear could end in settlement. If an agreement isn’t reached, the high court could strike down the CFPB’s use of the disparate impact theory in its scrutiny of rate participation programs.
The U.S. Department of Justice settled a lawsuit filed against the former Union Mitsubishi of Los Angeles. The suit claimed the dealer charged non-Asian customers higher interest rate markups.
In a bulletin issued today, the CFPB warned banking institutions that they could be on the hook for discriminatory markups imposed by dealers. The bureau’s notice also contains guidance on how finance sources should address fair lending risk.
Auto Advisory Services (AAS) launches today a new Multistate Audit Program by conducting its first compliance audits of automobile dealerships in New York and New Jersey.
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