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I am working on a cosourced fair lending audit, and we’ve noted some risk in how overages are applied by our indirect auto dealers. I know I’ve heard of some recent enforcement actions or litigation where banks were held accountable for their third party relationships’ pricing discretion. I am thinking there was even one that cited indirect auto dealing as the primary issue for the order (whatever it ended up being). However, I can’t put my finger on locating the publication of these actions. Any help locating would be greatly appreciated!
Here are some links you might find useful:
https://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=search&case=/data2/circs/9th/9756775.html
It’s an older case but I believe it talks about the issues you described. I briefly scanned over it.https://www.fdic.gov/regulations/examinations/supervisory/insights/sisum05/article04_auto_lending.html
This link is to some supervisory guidance issued by the FDIC on the subject of Indirect Auto Lending which might prove to be useful.https://www.fdic.gov/bank/individual/enforcement/
This link will allow you to look up enforcement actions handed down by the FDIC.https://www.occ.treas.gov/news-issuances/news-releases/2011/nr-occ-2011-28.html
This link will allow you to look up enforcement actions handed down by the OCC.I hope this helps.
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