Quick Q&A - We’re a fast-growing auto loan lender that provides in-house collection services. Would an automated CMS be an advantage, and do we need one?
Brian Larson's insight:
We’re starting out 2016 with a new weekly feature, the Compliance Quick Q&A. Each week we’ll take questions from our readers and pose them to our collection of really smart people. Let’s start off with this great question: "We’re a fast-growing auto loan lender that provides in-house collection services. Would an automated CMS be an advantage, and do we need one in place?"
Being as direct as possible on purpose, process and expectations of a corporate compliance initiative will help management understand what is expected.
Brian Larson's insight:
How clear is your compliance program? Being clear in all messages, materials and expectations makes it far easier to enlist middle managers as compliance advocates, and for them to communicate the information to their teams. http://hubs.ly/H01qCNw0
The Consumer Financial Protection Bureau, which has sharpened its enforcement of marketing services agreements this year, may be expanding its definition of a kickback to include any type of referral, according to a report from Barclays. "The CFPB seems to be taking the stance that referrals of any type are not a 'bona fide service' and that the exchange of anything of value tied to referred business could be considered a kickback," Barclays states in its U.S. Building Products & Homebuilding report. "This more aggressive . . .
In some cases, the debt had already been repaid by consumers, and in others the Norwell-based firm could not verify consumers actually owed anything, according to the U.S. Consumer Financial Protection Bureau.
In the ninth edition of the Consumer Financial Protection Bureau’s Supervisory Highlights, the bureau records that its actions resulted in $107 million in relief to more than 238,000 consumers. The report includes details on exactly where servicers and originators violated rules.
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