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Auto lending has been on regulators’ radar for a number of years as an enhanced-risk lending sector. In particular, the Office of the Comptroller of the Currency has been discussing auto lending in its Semiannual Risk Perspective since 2012. Considering that credit unions have a sizeable share of the auto lending market (roughly 20% of the outstanding balance), it is important that this message of enhanced risk be effectively communicated to the credit union industry. ALM First proposes not abandoning the asset class, but ensuring prudent underwriting and lending practices, especially with respect to indirect auto lending.

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