Third-Party Servicing of Indirect Vehicle Loans

The Wisconsin Credit Union League is writing in support of the NCUA's proposal to remove or revise regulatory limits on indirect vehicle loans serviced by third parties. They argue that the current limits impose unnecessary regulatory burdens and that credit union boards are better equipped to manage their own risk profiles and operational flexibility.

The National Automobile Dealers Association (NADA) supports the NCUA's proposed rule to remove rigid caps on the aggregate amount of indirect vehicle loans a credit union may purchase from a single servicer. They argue that reducing these regulatory burdens will increase competition, provide more affordable financing options for consumers, and support small-business dealerships.

America’s Credit Unions supports the proposed rule to remove regulations regarding third-party servicing of indirect vehicle loans. They argue that the current rules are overly prescriptive and create a competitive disadvantage for federal credit unions compared to state-chartered institutions, and that removing them will provide necessary flexibility and regulatory parity.

The Cooperative Credit Union Association, Inc., representing approximately 200 credit unions, supports the NCUA's proposal to delete portfolio concentration limits for indirect auto loans. They argue that the current "one-size-fits-all" limits are overly prescriptive and that credit union boards are better positioned to manage risk based on their specific profiles and the performance of lending partners.

The League of Credit Unions & Affiliates supports the NCUA's proposal to rescind regulations regarding third-party servicing of indirect vehicle loans. They argue that the current prescriptive limits are unnecessarily burdensome and that existing supervisory frameworks and due diligence requirements are sufficient to manage risk while providing credit unions with greater operational flexibility.

The California and Nevada Credit Union Leagues support the proposed repeal of regulations governing third-party servicing of indirect vehicle loans. They argue that the current prescriptive concentration limits are outdated, create unnecessary administrative burdens, and that a principles-based supervisory approach is more appropriate for modern risk management.

The Utah Credit Union Association supports the NCUA's proposed repeal of regulations governing third-party servicing of indirect vehicle loans. They argue that the current prescriptive concentration limits are outdated, create unnecessary administrative burdens, and can be replaced by a more modern, principles-based supervisory approach that allows for greater operational flexibility and competitive equity.

The National Association of State Credit Union Supervisors (NASCUS) supports the proposed rule to remove prescriptive concentration limits on third-party servicing. They argue that the changes provide credit unions with greater flexibility to manage risk according to their own strategic goals and that existing supervisory processes are sufficient to address associated risks.

The Ohio Credit Union League (OCUL) supports the NCUA's proposal to remove prescriptive regulations regarding third-party servicing of indirect vehicle loans. They argue that these rules are outdated, that credit unions have demonstrated the ability to manage these risks safely, and that removing the requirements will reduce regulatory burden while providing boards with greater operational flexibility.

Sun East Federal Credit Union supports the proposed rule to eliminate the 50% limit on the purchase of indirect vehicle loans from a single servicer. They argue that the credit union can manage its own concentration risk and that this change allows for better management of the balance sheet and stronger relationships with trusted partners.