Last year, the Consumer Financial Protection Bureau (CFPB) issued guidance on credit discrimination in the indirect automotive finance market, putting dealerships and lenders on notice about potential audits and punishments. In response, Dealertrack recommended that dealers adopt and implement an Equal Credit Opportunity Act (ECOA) Fair Lending Policy, including complete documentation of any deviation from a dealer’s buy rate markup policy.
To help dealership develop a fair lending policy and better defend themselves in credit discrimination audits, Dealertrack made an Exception Rate Justification Form available to its Compliance solution subscribers last year. Today, for the first time, this form is available online to its subscribers.
