As the federal Consumer Financial Protection Bureau (CFPB) continues to advance aggressively against auto lenders and thus auto dealers, it is imperative management reviews how it handles and complies with federal Fair Credit Reporting Act regulations Adverse Action Letters and Risk-Based Pricing Notices, stresses Terry Dortch, CEO of Automotive Compliance Consultants.
To help auto dealers more easily create and dispatch required notices to consumers who purse credit through them, Automotive Compliance Consultants Inc. offers an automated process to issue Adverse Action Letters and Risk-Based Pricing Notices as part of its management solutions.
Automotive Compliance Consultants helps dealers attain compliance with all federal laws and avoid penalties, fines and civil actions associated with noncompliance.
Dealers using this handy web-based service will quickly comply with Red Flag and OFAC regulations for customers seeking credit through them. Consumer information thus captured populates Adverse Action Letters or Risk-Based Pricing Notices if required.
- Adverse Action Letters: Must be sent to anyone who applies for credit and is denied. Or, when the terms are different from that requested. In most situations, the bank with which the dealership has pursued financing for the customer will produce and distribute this notice. However, in situations where the dealer makes the credit decision or denies credit without shopping the application to a bank or finance company, the dealer is required to take the action.
- Risk-Based Pricing Notices: Dealers are required to provide a Risk-based pricing notice to customers who receive credit on material terms that are less favorable than terms offered to a substantial portion of their customers. In the alternative, an Exception Notice must be delivered to all customers that request credit from the dealership prior to the agreement being entered into.
Automotive Compliance Consultants specializes in dealership compliance, providing in-dealership consultations and analysis, compliance audits, training and offers solutions for all compliance needs. The Automotive Compliance Consultants staff has extensive experience in the retail automotive industry and focuses exclusively on dealership compliance issues. For more information, contact Terry Dortch at [email protected] or visit www.compliantnow.com.