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Regulating e-Lending Compliance Issues

OnDemand Webinar (85 minutes)

Gain a better understanding of the regulations that must be considered as part of an e-lending program and how best to ensure a compliant program.

Currently, there are a growing number of financial/technical companies (fintech) that have been developed as lending platforms. The goal of fintech companies is to disrupt the current financial system. In particular, these lending platforms change many of the traditional roles in loan underwriting including in person visits, significant documentation and the time is takes to process an application. However, despite the changes being driven by fintech companies, the regulations and rules that apply to lending have not significantly changed. For an institution that is considering a partnership with a fintech company, there are regulations to consider. This information addresses the regulations that must be considered as part of an e-lending program and how best to ensure a compliant program.


James DeFrantz, CRCM, CAMS, J.D., Virtual Compliance Management


E-Lending Is the Future for Consumer Lending (and a Big Swath of Commercial Lending)

• There Is a Huge Pool of Underbanked and Unbanked Persons in the U.S.

• Underbanked and Unbanked Are Turning to Fintech to Meet Their Banking Needs

• Today's Customer Wants Speed in the Decision and Delivery of $$

• The Types of Credits Being Sought Are Different

E-Lending Is Delivered Differently From Traditional Lending - but the Same Rules Apply

• The Three "C's" of Credit (Capital, Character and Capacity) Are Getting a New Look

• Using the E-Lending Platform Doesn't Allow for the Same Level of Knowledge of the Customer to Meet the Customer, This Can Be Both Good and Bad

• Despite the New Look, Regulation B, Fair Lending and UDAAP Will Still Apply

Lending Compliance - a Brief History

• Compliance Regulations Are Designed to Address Past Specific Problems

• The Point of the Regulations Is to Make Sure That Financial Institutions Are Fair in Their Credit Decisions

• Regulations Require Accountability

Vendor Management and E-Lending

• Developing a Relationship With an E-Lender Is the Most Efficient Way to Add the Product

• Vendor Management Rules Apply

• The Lender Is Responsible for the Actions of the Vendor

• Testing the Results

Fair Lending, ECOA and Various Issues

• Testing/Using Scoring Systems

• Reviewing Adverse Actions and Pricing

• BSA and CIP Issues

• Other Considerations (UDAAP, Pricing)


• E-Lending Is the Future

• E-Lending Is Delivered Differently, but the Rules Are the Same

• Lending Compliance Rules Serve a Purpose

• Vendor Management Is Key

• Dealing With Specific Issues