January 13, 2014

CUs' vendor fair-lending risks detailed

Credit unions that viewed Monday's NAFCU webcast on managing third-party fair lending risks learned the importance of monitoring and training third-party vendors to protect their own financial institutions from unnecessary risks.

David Reed, NAFCU Certified Compliance Officer and partner, Reed and Jolly PLLC, discussed the importance of third-party vendors to credit union operations but also stressed the importance of monitoring those vendors. "Third parties play an integral part in credit union operations," he said. But he noted that any third-party vendor introduces risk to credit union operations. He said credit unions need to understand that there is a "noticeable and measurable amount of risk in our third-party relationships."

He said credit unions should not assume third parties are doing all they can to prevent fair lending violations, nor should credit unions take violations lightly. Reed noted that the implications of a violation can be dangerous and include financial loss, regulatory involvement, litigation and reputational damage.

To protect credit union operations and create best practices for the vendor/credit union relationship, Reed recommends:

  • strong procedures between the vendor and the credit union;
  • comprehensive contracts and agreements between parties;
  • regularly monitor both internal and external reports;
  • verify fair lending training participation by the vendor;
  • review and address complaints regarding potential pricing discrimination;
  • review policies, procedures, rate sheets and vendor agreements to determine the level of discretion provided in loan pricing; and
  • review agreements to determine whether financial incentives are based on the price of the loans.

NAFCU's on-demand webcasts are available for up to 12 months after the live broadcast, and are included in your registration price. They are also included in NAFCU's 2014 unlimited webcast subscription.