Category Regulatory Compliance

Lady Redundant Woman

If you have younger kids, you may have seen the TV show Word Girl. One of the villainous characters is called Lady Redundant Woman. Lady Redundant Woman obtained the powers of duplication when she was fused with a copy machine. As you might expect, she often speaks in redundancies. Why this education in unusual children’s […]

An update on the CFPB

We’ve been silent for awhile on the subject of lending discrimination and the CFPB, but that doesn’t mean the rest of the lending world stopped talking about it. Today, for example, Toyota Credit announced that it has been accused of discrimination by the CFPB and the Justice Department. Like most of the recent claims against […]

CFPB Update: BMO Harris Bank switches to flat fee participation

With the CFPB pushing to change the dealer income model in the auto industry, it seemed inevitable that lenders would adjust.  The question was who would get the ball rolling?  The answer: BMO Harris Bank.  (For previous discussions of the fight between the CFPB and the auto industry, see all the links here.) As reported […]

As the CFPB turns

Schadenfreude – noun, often capitalized: a feeling of enjoyment that comes from seeing or hearing about the troubles of other people. Auto dealers everywhere, and possibly the banking industry in general, had to choke down some strong feelings of schadenfreude a couple weeks ago.  The CFPB, after months of emphasizing its proxy methodology for determining […]

Ally unexpectedly “wins” battle; war on dealer payments undecided

(For background on the auto dealer participation battle with regulators, see our previous posts on the topic.) As the brouhaha on auto dealer participation reached its peak in late 2013, the CFPB claimed a victory with a $98 million settlement of discrimination claims against Ally Financial.  But now that the details are out, it appears […]

CFPB Dealer Participation Update

When a regulatory body comes into conflict with industry powerhouses, fireworks are the result. And by fireworks, I mean a lengthy, sleep-inducing process punctuated by moments of double-speak and a complete failure to answer direct questions. Sorry. I just finished watching the Hearing on the Consumer Financial Protection Bureau’s Semi-Annual Report to Congress, which is […]

Participation Payments to Dealers Coming to an End?

Where loan origination is fragmented, payments get made to intermediaries for the services provided.  In some cases, those payments are clearly disclosed to borrowers as fees on the loan.  However, most of the time the cost of paying the intermediary is built into the borrower’s interest rate.  In the mortgage world, this is called yield-spread […]

Nobody “Likes” Compliance

If the world were Facebook, nobody would “like” regulatory compliance.  It is one of those costs of doing business that most prefer to spend as little time as possible thinking about.  Kind of like keeping stocked up on kitchen supplies. What makes regulatory compliance so unpopular isn’t just the burden and complexity.  It’s that it […]