For those of us concerned with federal fair lending laws, 2017 is shaping up to be an historic year. An unprecedented administration will assume control of the highest levels of government at the end of this week, and many Consumer Financial Protection Bureau watchers—myself included—are wondering what the next few months and years have in store for the consumer finance industry.
Will Trump oust Bureau Director Richard Cordray? Some even wonder if the POETUS could dismantle the CFPB and Dodd–Frank entirely, as he has alluded in the past. While most believe a complete teardown of the CFPB, Dodd–Frank, and the current Fair Lending framework is unrealistic, there will certainly be changes ahead.
With these enormous questions hanging overhead, the upcoming American Financial Services Association conference promises to be a can’t-miss event. Held just four days after the inauguration, the 21st Annual AFSA Vehicle Finance Conference and Expo finds an industry at a crossroads.
Make that multiple crossings between multiple roads. Last year was a record year for automotive sales. Dealers and their lending partners are wondering if the trend will continue, plateau, or decline in 2017, and to what degree. In light of uncertain business conditions and an even more unpredictable regulatory climate, there are sure to be plenty of lively debates and discussions between AFSA conference attendees.
For many auto dealers and lenders, this year’s AFSA conference is only the beginning of a larger exchange of ideas. The conference’s last day coincides with the first day of the National Automobile Dealers Association 2017 Convention and Expo, a 24,000-attendee event happening just a few blocks away.
Complí will have a presence at NADA, and a few of us are heading down to New Orleans early for AFSA. In keeping with our plans for NADA100, our AFSA emphasis this year is on meaningful conversations—about the CFPB, the regulatory changes coming our way, your outlook for 2017, and more.
Talk to Us
If you’ll be attending the AFSA conference, the NADA conference, or both, let’s talk. I encourage you to say hello and share your questions, concerns, and thoughts with us.
If you work for lending organization or partner with a capital provider, I would love to talk with you about your predictions for 2017 and beyond, and discuss regulatory trends and updates. We’ll talk about how every lender is on the CFPB’s radar, and why you can’t afford to ignore the responsibility of conducting periodic audits of your organization, vendors, and partners. As we’ve written before on this blog, the bar has been raised, and any gap in the complex lending and automotive sales chain can spell trouble for all companies involved.
Together, we will explore your unique compliance situation and identify what’s working and what could use improvement. Every lender must be able to prove that its clients have a sufficient compliance program in place. Would you be able to provide the necessary data were the CFPB to come knocking? Are you vetting third parties to a reasonable degree and holding them accountable?
If not, you may be inadvertently posing a risk to your bank—or to your clients. Yes, the costs of noncompliance reach beyond penalties, lawsuits, and reputational damage: a substandard compliance program could lose you your access to capital, effectively shuttering your business overnight.
Are you confident that your organization’s and your clients’ compliance programs are robust enough? Can you prove it?
Think about those question from now until AFSA begins on January 24th—then come find us on the show floor. We would be happy to talk with you and point you toward a custom solution for your organization.