Tag: CFPB

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Compliance F&I

Are You In Control of Your Profit Potential?

Karen Klees, Certified Consumer Credit Compliance Professional, EFG Companies

 

Contributing Author: Karen Klees, Certified Consumer Credit Compliance Professional, EFG Companies

If you’ve been paying attention to industry news, you probably know about the Federal Trade Commission once again setting its sights on add-on products. While large industry players expected this on the heels of the CFPB’s increased oversight into auto lending practices, many dealerships looking to make up for lost dealer reserve with the sale of F&I products are looking to tighten up their policies and procedures.

If you haven’t already begun re-evaluating your compliance procedures, now is the perfect time! While there are many elements to consider as you review your current policies and procedures for your existing product offerings, there is an upside. When sold in a compliant manner, F&I products provide dealers the ultimate control in their profit potential.

This being said, applying compliance standards and scrutiny to your policies and procedures is growing in importance.  A recommended starting point, as you evaluate your product offering, is to ask a simple question:  Do your products’ benefits fulfill a real and mathematically calculable customer need? 

Starting with this premise, here is a checklist to perform due diligence:

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F&I

Automotive News – Consistent F&I Pricing Key to Compliance

Jim-Henry

 

Contributing Author: Jim Henry, Automotive News Special Correspondent

As regulators scrutinize auto lending practices, companies in the F&I space have made compliance with state and federal rules a priority too.

F&I product administrator EFG Cos., of Dallas, is one such company. About a year ago, it appointed Karen Klees to fill the new role of compliance specialist. Klees recently amended her title to certified consumer credit compliance specialist after completing the Consumer Credit Compliance Certification Program from the National Automotive Finance Association.

Klees explained to Automotive News Special Correspondent Jim Henry how she would put her training to work at dealerships in 2015.

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The talk at auto finance industry conferences centers on compliance as the growing arena in the CFPB era. Is that your experience, too?

Everyone I’ve come into contact with recently has identified … stresses they are under from the Consumer Financial Protection Bureau and other regulators. It’s been a huge kind of coordinating task.

At the same time, the industry says it didn’t just discover compliance, right?

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Categories
Compliance

Compliance in 2015

Karen Klees, Certified Consumer Credit Compliance Professional, EFG Companies

 

Contributing Author: Karen Klees, Certified Consumer Credit Compliance Professional, EFG Companies

2015 is here and the CFPB is keeping up the pressure on compliance regulation. Everyone is wondering what the year will look like. Will more lenders implement flat rates? Will the CFPB find a way to extend their influence into the F&I space? Will Congress step in and impose restrictions on the CFPB? With so much up in the air, dealerships and lenders alike are waiting with baited breath to see what 2015 has in store.

Instead of waiting, it’s time to focus on and hone your operations. While many dealers have already begun decreasing their reliance on finance reserve and pushing for more product sales, you can bet that the CFPB is looking into how to branch into that area. In fact, in 2014, the CFPB reached a consent agreement with an F&I vendor and a lender, where each entity was required to issue reimbursements to contract holders for using ambiguous language in the product sales process, such as “This product will only add a few dollars to your monthly payment.” The CFPB stipulated that the exact price of the product is necessary in the product presentation, not generalities.

While the CFPB’s influence lies primarily with the lending community, they have been clear that lenders are also responsible for the actions of the vendors and partners with whom they choose to do business. This applies to who they use to service and collect their loans, as well as who originates them. So far, they have focused for the most part on rate administration as it relates to origination, but as we saw in 2014, they also took issue with the sales practices of ancillary products. To protect your dealership and keep operations running smoothly, take a deep look at your F&I product presentation with your legal team and address any issues that may arise.

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