Category: Compliance

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Compliance

CFPB – A Year in Review

Contributing Author: Steve Roennau Vice President Compliance EFG Companies
Contributing Author:
Steve Roennau
Vice President
Compliance
EFG Companies

A lot has happened with the Consumer Financial Protection Bureau (CFPB) in the past year. From large settlements to court rulings, the CFPB brought itself under the spotlight.

Let’s start at about this time last year. The House of Representatives passed H.R. 1737, the “Reforming CFPB Indirect Auto Financing Guidance Act” with a strikingly majority vote of 332-92. The piece of legislation would direct the CFPB to amend how it issues guidance to indirect auto lenders by:

  • providing a public notice and comment period before issuing the guidance in final form;
  • making publicly available all information relied on by the CFPB, while also redacting any information exempt from disclosure under the Freedom of Information Act;
  • consulting with the Board of Governors of the Federal Reserve System, the Federal Trade Commission, and the Department of Justice; and,
  • study the costs and impacts of the guidance to consumers, as well as women-owned and minority-owned small businesses.

In addition, the bill would nullify the CFPB’s “Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act Bulletin”. This bulletin instructed lenders to either eliminate dealer pricing discretion, or constrain dealer pricing discretion by monitoring dealership practices and using “controls” to force dealerships to adjust their practices.

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Compliance Featured

EFG Companies Fortifies Dealer and Lender Data Security Through SSAE 16 SOC 1 Certification

soc-service-org_b_marks_2c_webEFG’s Continued Leadership in Both Compliance and Technology Sets Industry
Bar for Customer Service Excellence

EFG Companies, the innovator behind the award-winning Hyundai Assurance program, announced today it has been awarded the Service Organization Control 1 (SOC 1) Certification under the Statement of Standards for Attestation Engagements 16 (SSAE 16) guidelines from the American Institute of Certified Public Accountants (AICPA). This certification represents another significant achievement in EFG’s ongoing commitment to ensure industry-leading compliance for its clients and customers.

SSAE 16 is the most widely-recognized standard providing companies with a method for reporting information about the design and operation of internal systems and controls relating to privacy and security regulations.  SOC 1 reports are designed to certify whether a company utilizes uniform and reliable safeguards as a processor of data belonging to their clients and customers.

For EFG to obtain the SSAE 16 SOC 1 certification, more than 70 processes that could affect data security and business flow were evaluated. Examples of the processes evaluated include:

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Compliance

Benefits of Documenting Your Dealership Processes

Contributing Author: Steve Roennau Vice President Compliance EFG Companies
Contributing Author:
Steve Roennau
Vice President
Compliance
EFG Companies

As a dealer, you’ve probably heard that it’s important to document your processes seven different ways. The Consumer Financial Protection Bureau (CFPB) is rallying for them. Lenders are asking for them. And, soon it will be a requirement for all dealers to have documented processes.

But what does this mean? I get a lot of questions from dealers asking some variation of, “Do I just need to document my processes with regards to regulations, or all my processes?” In short, the answer is invariably, “You need to document all your processes.”

But, here’s the kicker: there are so many processes in a dealership that not everyone knows where to begin. And, so many processes are simply just part of the routine, that many dealers haven’t conceptualized how to define them beyond, “just do it”.

Just like with any big project, think about tackling this project one bite at a time. Start with the checklist on your deal jackets. Define and write down the process behind each item on the list. Each process should consist of three components:

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