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.

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 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 Endangered Small Credit Union Defense (ESCUD), a nonprofit advocacy organization, supports the proposed rule to eliminate prescriptive concentration limits and waiver processes for third-party servicing of indirect vehicle loans. They argue that removing these rigid regulations will reduce administrative costs and provide small credit unions with the flexibility to manage risks proportionately to their size.