Dealer Participation (Markup)
NOTICE: The information below was obtained directly from the Consumer Financial Protection Bureau’s (CFPB) Paper on the Equal Credit Opportunity Act (ECOA) and Regulation B
- Dealers’ policy for setting the amount earned for arranging financing must not have a negative disparate impact on customers in a protected class.
- Dealers should have a written policy setting out the amount of participation and the specific circumstances under which the participation rate may be lowered.
- The NADA, the American International Automobile Dealers Association and the National Association of Minority Automobile Dealers Association have developed a “Fair Credit Compliance Policy & Program” paper that provides guidelines and sample forms for dealers.
Click here for the “Fair Credit Compliance Policy & Program” documentNADA-AIADA-NAMAD Fair Credit Compliance Program (7-15)