Informed’s Compliance Solutions keep you Informed

Informeds Compliance Solutions keep you Informed Informed

AI-generated image from Midjourney representing Informed’s compliance

We help many of the nation’s largest lenders automate the review and processing of loan applications. And a big part of what we do is assure Informed’s compliance solutions are up to date with federal and state regulations.

Informed’s compliance verifications use advanced machine-learning techniques to read deal jacket documents and confirm that required disclosures, signatures, and key terms are present. We do this in minutes, as opposed to the usual hours needed for a manual compliance review. In addition, our technology is fast, accurate, and consistent.

Here’s a representative sample of our clients’ compliance checks:

Truth in Lending Act

  • We offer robust checks to assure the loan offer is compliant with the Truth In Lending Act, Regulation (Z) including determining whether:
    • The amount finance is listed
    • The itemization is complete
    • The finance charge and APR are present
    • The monthly payment amount, the number of monthly payments, the base vehicle cash, and the total amount of payments (and the total) is listed. 

DOT Federal Odometer Regulations

  • We check that the deal complies with Federal odometer disclosure rules confirming whether the odometer statement matches the:
    • contract’s VIN
    • contract’s mileage
    • applicant’s and co-applicant’s name, and is
    • Is sIgned by applicant and co-applicant

Fair Credit Reporting Act

    • We check to see if the lender has documented permission from the applicant to pull their credit report

Know Your Customer Rules

  • We support lender obligations to verify the identity of their customers by confirming that:
    • The driver’s license, passport, or other US federal or state identification matches the applicant’s name and is current;

We also cover the field when it comes to complying with state obligations.

State GAP laws

  • Federal regulators carefully scrutinize the sale and servicing of GAP Waivers and Insurance. Our technology has automated compliance with State GAP and notice requirements.
    • GAP Liability Notice and Disclosures:  We check the four corners of the GAP Disclosures and Liability notices by confirming that they:
      • Match the applicant’s/co-applicant’s name
      • Is signed by the applicant/co-applicant, and
      • Match the contract’s VIN, GAP term, and GAP premium

State Documentary Fee Caps

  •   Multiple states put limits on how much lenders can charge for processing documents or other public official fees.
    • We check to make sure the doc fees and public official fees (e.g., title, registration fees, license fees) are compliant with state requirements. 
  • Co-signer notice  A number of States including CA, AZ, CO, IL, IA, ME, and NYC require loan co-signers to be given a notice explaining their obligations. Where required, we confirm the presence of these notices.
  • California Vehicle Cancellation Option: California used-car dealers must offer a two-day contract cancellation option. We check to ensure it’s present. 
  • Proof of Foreign Language acknowledgment: Where States require a Proof of Acknowledgement that a transaction was conducted in a foreign language, Informed automatically checks for whether the acknowledgement is:
    • Signed by the applicant
    • Matches the applicant’s name, and 
    • Identifies the language in which the negotiation occurred.

What’s in your deal jacket? And how can we help?

author avatar
Tom Oscherwitz VP of Legal
Tom Oscherwitz is Informed’s VP of Legal and Regulatory Advisor.  He has over 25 years of experience as a senior government regulator (CFPB, U.S. Senate) and as a fintech legal executive working at the intersection of consumer data, analytics, and regulatory policy.

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