Anticipated regulation from the CFPB is expected to require lenders to determine a borrower’s ability to repay (ATR) prior to providing a covered loan1. FactorTrust is committed to helping lenders meet the ATR requirements efficiently. We have resources dedicated to understanding the market, talking to customers and looking at ways to help lenders improve their business.
FactorTrust’s new platform, LendProtect ATR, provides informed lenders with a comprehensive solution that will accelerate their ability to add the needed information and tools to meet the regulators’ new ATR underwriting and reporting requirements.
With LendProtect ATR a lender may quickly compare Residual Income to the requested loan amount to determine if a consumer has the ability to repay.
This flexible platform streamlines the integration of core data sets including covered loan data, traditional bureau data, and validated living expense data. The solution accommodates very specific lender rules or requirements, and most importantly, simplifies the management efforts for the lender. FactorTrust does not stop there, we’re doing a lot more to make sure the platform delivers on the promise to help lenders manage the ATR process cost-effectively.
Access numerous data sources, including stated and modeled sources, to accurately assess monthly income and living expenses and determine a comprehensive list of expenses across leading traditional and alternative credit sources.
The platform streamlines the integration of new data and is 100% configurable. Information may be used independently or packaged to leverage a waterfall decision support infrastructure to help verify residual income.
The platform accommodates unique rules, requirements and formulas. For example, for the residual income calculation, a lender will be able to configure their output response to deliver a yes/no or a percentage value.
The solution is easy to implement and scales with the lender’s business. Importantly, it is less intrusive to a lender’s business.
1 The CFPB has published a proposed rule that would apply to certain short-term and longer-term credit products: (1) loans with terms of less than 45 days (“shorter-term loans”); and (2) loans with terms longer than 45 days and APRs in excess of 36%, where the lender has access to the borrower’s deposit account, paycheck or auto title (“longer-term loans”). http://files.consumerfinance.gov/f/documents/Rulemaking_Payday_Vehicle_Title_Certain_High-Cost_Installment_Loans.pdf