LAS VEGAS – According to Tami Wass, vice president of lending, Golden West CU, and who spoke at CU Direct Lending’s 2006 Annual Symposium, the following are the leading 10 indirect lending characteristics NCUA does not want to find when it audits a credit union: 1. It exceeds regulatory guidelines, doesn’t follow the Federal Credit Union Act, or doesn’t follow its own bylaws. 2. It has an inadequate indirect lending policy. 3. It isn’t following its own indirect lending policy 4. It has inadequate internal controls. 5. It has inadequate separation of duties of its loan officers and other employees. 6. It has an inadequate system of reports and analyses. 7. It has no dealer contracts. 8. It has no due diligence process. 9. It isn’t proactive. 10. There’s a lack of formal response to agreed upon actions.

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