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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!
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