Compensation and Compliance Matters: A Reminder of the Risks from Lending Through Third Parties
May 20, 2014
Last month, BMO Harris Bank changed policies on auto lending to pay a flat percentage of the loan amount to auto dealers making loans (sound familiar?). While the bank was under no obligation to do this and no other auto lenders have followed suit, the bank’s rationale should not escape the attention of lenders having active third-party origination channels.
The fact is, lenders with TPO channels have as much if not more legal risk from the actions of TPO partners as they do with their own originators. In other words, if a broker violates fair lending laws, the lender can be held responsible even though it did not originate the loan. Click here to read the entire article If you have any questions about please contact Ari Karen at: firstname.lastname@example.org | 240.507.1740 Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others. You can also connect with Offit Kurman via Facebook, Twitter, Google+, YouTube, and LinkedIn.