Voluntary Protection Products – Lender Best Practices to Address the Compliance Risk
Over the last several years, scrutiny placed on lenders in connection with the financing and servicing of voluntary protection products (add-ons) has increased tremendously. Recently, the industry has seen an increase in activity on the regulatory, litigation, and legislative front in connection with these products. The CFPB and other regulators have concluded that lenders must proactively process GAP waiver and CLAH refunds upon early termination of the finance agreement in all 50 states or risk a UDAAP finding.
Moreover, many lenders are being required to lookback on loans that terminated early, and which included a GAP waiver or CLAH policy to determine whether a refund was processed on these products. Faced with the complex regulations governing these products at the state and federal level, lenders continue to evaluate how best to address the increased risk associated with the financing and servicing of these products.
Join Stephen McDaniel, Co-Founder and CEO, and Rick Hackett, former CFPB Assistant Director & F&I Sentinel Board Member, to hear and discuss best practices to address the ever-changing and complex issues associated with the financing and servicing of voluntary protection products, and how best to prepare your company for its next regulatory exam.
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April 19th, 2023 by gmcgurn@afsamail.org
