Early GAP refund status updates critical to multistate compliance

PLANO, Texas — Early updates on GAP waiver refund status are key to lenders remaining compliant across varying state requirements. 

“There’s 50 different states doing [refunds] 50 different ways,” Robert Christini, senior director of lender solution sales at Cox Automotive, said on a panel discussion during the Non-prime Auto Finance Conference. “Lenders need to look at a uniform way to have a clean process in place [for refunds], because this is not stopping.” 

Lenders should create a process to check on the status of refunds in advance of the deadline set by states for consumers to be reimbursed, Peter Krall, vice president at Allied Solutions, said during the discussion. 

“Have a process in place that by day 45, if that refund has not been issued and there’s no evidence of that refund making it to the consumers, have a process in place whereby you as the lender or servicer can take corrective curable action before you’re out of compliance,” Krall said. 

Validating the status of the refund at day 45 keeps the lender consistent across each state’s deadline, he said.  

The Big Wheels Auto Finance Data 2023 report, the only tabulation of the top 200 auto lenders by outstandings, is available now.