Indirect Lending

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Indirect Lending

Compliance Couriers

Don’t make the same HMDA mistakes Bank of America did

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FinCEN eases beneficial ownership verification at each new account opening

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NCUA amends rules on loan participations & indirect lending

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NCUA launches Round 8 of its Deregulation Project

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Federal Regulations

CFPB: 12 CFR 1026

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FTC: 16 CFR 433

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Wis. Admin. Code: DFI-CU 61

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Federal Statutes

Wis. Stats: 422 WCA – Consumer Credit Transactions as regarding credit sales.

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Wis. Stats: 425 WCA – Consumer Transactions – Remedies and Penalties as regarding credit sales.

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ii Releases

0159 BSA: Customer Identification Program and Customer Due Diligence

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B063 FTC Rule on Preservation of Consumers’ Claims and Defenses

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Letters to CUs

NCUA: Letter to Credit Unions No. 10-CU-15 – Indirect Lending and Appropriate Due Diligence (August 2010).

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OCU: Letter CU 1-14 – Dealer Indirect Paper (January 8, 2014)

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Resources

America’s Credit Unions: e-Guide – Holder In Due Course Rule

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CFPB: Bulletin 2013-02: Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act (3/21/2013)

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Other

Dealer Sample Agreement with Instructions (05/27/03)

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