{"id":400,"date":"2015-02-25T12:57:30","date_gmt":"2015-02-25T18:57:30","guid":{"rendered":"http:\/\/efgintelligence.com\/subprimepoint\/?p=400"},"modified":"2016-01-21T16:29:57","modified_gmt":"2016-01-21T22:29:57","slug":"control-advantage-non-interest-income","status":"publish","type":"post","link":"https:\/\/efgintelligence.com\/lendingcurve\/control-advantage-non-interest-income\/","title":{"rendered":"Control is an Advantage with Non-Interest Income"},"content":{"rendered":"

\"Karen<\/a><\/strong><\/p>\n

 <\/p>\n

Contributing Author: Karen Klees, Certified Consumer Credit Compliance Professional, EFG Companies<\/h3>\n

In a new world order of uber-competitive interest rates and shrinking profit margins, a significant number of lenders are supplementing revenues by promoting and marketing privately-labeled consumer protection products.<\/strong>\u00a0 While still reeling from the implementation of formal compliance processes relative to financing, discussion has grown louder regarding FTC and CFPB involvement in the oversight of the sale of F&I products.<\/p>\n

There are many elements to consider as you review your current policies and procedures for your existing product offerings.\u00a0 On a positive note, having a suite of private-labeled products provides the ultimate control in pricing (and profit), and significantly more control in making sure your product offering passes the litmus test from a consumer perspective.<\/strong><\/p>\n

This being said, applying compliance standards and scrutiny to the partners you have chosen to be a third party administrator or insurer is growing in importance.\u00a0 A recommended starting point, as you evaluate or re-evaluate product offering, is to ask a simple question:\u00a0 Does the product\u2019s benefits fulfill a real and mathematically calculable customer need (or have risk)?<\/strong> <\/p>\n

Starting with this premise, here is an additional checklist to perform due diligence:<\/p>\n