Trump, the CFPB, and Demonstrating Compliance to Your Bank—What We’re Looking Forward to at the AFSA Independents Exposition 2017
“Embrace change.” Besides being generally good life advice, that mantra also encapsulates the theme of the American Financial Services Association Independents Exposition 2017.
Developed by the AFSA Section on Independent Operations, the expo is, in the association’s words, “the main event for independent consumer and sales finance companies, including traditional installment lenders providing personal loans and subprime auto finance companies that purchase contracts from independent and franchise auto dealers.” Organizations of all regions and sizes will be in attendance, as will companies that serve the industry.
Which brings me to us. Just as we’ve done for prior AFSA meetings and related industry events, Compli will be heading to the expo later this month, catching up with friends and clients, and holding meetings with parties interested in adopting a more efficient, defensible approach to fair lending compliance. It’s more than serendipity that our platform, Compligo, is engineered to adapt to new laws, regulatory shifts, and workforce needs as they happen—helping your business embrace change rather than fight against in.
Here are a few topics I anticipate we’ll dig further into at the AFSA Independents Exposition:
The Imperative to Demonstrate Fair Lending Compliance to Financial Institutions
As we’ve mentioned before on this blog, it’s not just the CFPB who is paying attention to your compliance program. Big banks conduct semiannual audits of their indirect lending clients, and if they find that your CMS is not up to par, your operating capital could evaporate. The CFPB has indicated that every organization they regulate is responsible for its third parties, and the possibility of non-compliance may compel a bank to walk away, absolving them of risk but also revenue-generating relationships. I look forward to speaking with representatives of banks and capital providers about the ways in which Compli can keep them off the CFPB’s radar, secure their client relationships, and insulate both their organizations and end clients from risk.
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Regulations Under the Trump Administration
Three months into Donald Trump’s tenure, there’s no doubt where the President and his administration stand on regulations, but we’ve seen little action up to this point. Are we stuck in a holding pattern, or is massive, disruptive change around the corner? Our Commander-in-Chief and the tone he’s setting for Washington, DC’s regulatory agencies will be frequent topics of discussion at the expo. I’m looking forward to the multiple sessions on the event schedule focused on Trump’s promises and actions in office, as well as the ways in which politics reverberates through all our lives.
The Future of the CFPB
Related to the previous topic: What’s next for the CFPB? We’ve explored this question in recent webinars and articles, and I expect that the narrative will continue to develop through conversations at the expo next week. We know that the CFPB’s structure was declared unconstitutional, that one of its guiding regulatory theories—disparate impact—was clarified and challenged by the judiciary, and that the agency is shifting its focus somewhat from direct enforcement to regulatory guidance. What we don’t know is whether individual states and the Department of Justice will step up their enforcement, or to what extent.
I look forward to hearing from AFSA EVP Bill Himpler, who does a tremendous amount of work with the CFPB and regularly testifies before lawmakers on behalf of lenders. (By the way, we produced a webinar with Bill about the CFPB, and our most recent webinar featured Michael Benoit of Hudson Cook—also an AFSA participant and speaker—so catch up at our Resource Library before this year’s conference.)
If you can’t attend this year’s AFSA Independents Exposition, we can offer you the next best thing in the form of a recap here on the blog later this month. If you are attending, we’d love to set aside some time to connect and talk about your compliance needs—contact us to schedule an appointment.