CRA provided fair lending analyses for a major automotive lender in response to a DOJ investigation and separate class action litigation. The DOJ closed the investigation without bringing charges against the client. In multiple engagements for captive finance arms and their parent companies, we performed several detailed financial analyses of the automotive retail channel.
Community credit needs assessments—why now?
The CFPB has discarded the statistically based analyses that were key to investigating and uncovering systematic patterns. While institutions may find the...