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HOT TOPICS
2016
MEMBERSHIP
DIRECTORY
81
NADA FAIR CREDIT COMPLIANCE PROGRAM FOR DEALERS
NADA has led the charge in defending the dealer-assisted financing model, and is working to prevent the
adverse consequences that government-imposed flat fees would cause for consumers, dealers and finance
sources alike. To help dealers, NADA has prepared educational resources to strengthen their efforts to comply
with fair credit laws.
This publication provides essential background on this issue, sets forth a fair credit compliance programtemplate
that a dealer can adopt, and contains both general and specific instructions for completing the program
template. Among many other features, the program template (a) sets forth a fair credit policy that states the
dealer’s unambiguous commitment to fair credit compliance; and (b) establishes a voluntary standardized
method for determining the amount of dealer compensation that may be earned in a credit transaction.
The
compensation
method
is based on one that was
adopted by dealers to resolve
Depar tment
of
Justice
allegations of unintentional
credit discrimination. It generally
involves establishing a set
amount of dealer participation
that a dealer adds to a buy
rate and only deviating from
that amount if certain pro-
competitive factors that are
unrelated to the consumer’s
background are present in the
transaction and are properly
documented.
Dealers can access a PDF
of the NADA Fair Credit
Compliance Policy &
Program at www.nada.
org/regulatory_affairs/
faircreditlanding
Thank you to NADA for this article.