The Consumer Financial Protection Bureau (CFPB) provided guidance to indirect auto finance lenders earlier this year of the CFPB’s requirement for compliance with the Equal Credit Opportunity Act (ECOA). The CFPB is basing its guidance on the theory of “disparate impact”, or unintentional discrimination.
Some dealers have received letters from national lenders advising them that their portfolio may indeed have disparate impact tendencies against those protected under the Equal Credit Opportunity Act.
gvo3 & Associates now offers a Disparate Impact Virtual Review. This review mimics the lender’s statistical analysis, using the same assumptions the lenders are using to determine whether the dealer’s originations exhibit traits of disparate impact. Our review then takes the next step – we disprove or prove the lender’s assertion. If the result of the gvo3 Disparate Impact Virtual Review is that the dealer’s portfolio does not contain elements of disparate impact, our report of findings can be used to present to a lender or regulator. This demonstrates to the lender or regulator that the dealer was notified of a potential issue and, after investigation by an outside party, the allegations were not substantiated. If the result of the gvo3 Disparate Impact Virtual Review, however, is that the dealer’s portfolio does appear to contain elements of disparate impact, gvo3 & Associates provides the consulting capabilities to put corrective actions and process in place to address the allegations. Then, if a lender or regulator pursues the issue, a dealer can show that it was notified of an issue, investigated the allegations and put corrective actions into place. Call (312) 961-9065 or Email us for details and pricing.