Carleton survey illuminates ‘compliance confidence crisis’ as states intensify oversight of rate calculations & more
Tim Yalich is vice president of business development at Carleton. Images courtesy of the company.
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Carleton said findings from a nationwide survey the provider of compliant loan calculation and disclosure solutions conducted in March showed a “widespread compliance confidence crisis.”
What triggered an auto-finance version of March Madness? Carleton explained its survey results stemmed from a dramatic shift toward state-level regulatory oversight and systemic vulnerabilities in how organizations validate lending calculations.
The online survey, presented to more than 2,000 financial services and automotive lending professionals, found that the regulatory landscape has fundamentally changed, according to Carleton.
A total of 73% of respondents reported that state regulators have been more active than their federal counterparts over the last 24 months. It’s a development Carleton said has “profound implications for any organization operating across multiple jurisdictions.”
Compounding this challenge, 89% of survey respondents indicated that regulatory changes requiring system or calculation updates occur frequently or almost always, “underscoring the relentless pace of change that compliance teams are being asked to absorb,” according to Carleton.
Perhaps the most striking finding is the prevalence of APR errors under the Truth in Lending Act (TILA).
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Carleton discovered 72% of organizations identified at least one loan requiring an APR reimbursement under TILA in the past 12 months alone.
“These are not only hypothetical risks, but they also represent active, ongoing compliance failures with direct financial and legal consequences,” Carleton said.
The company indicated the most commonly cited drivers of calculation errors align with longstanding industry pressure points, including:
—Incorrect application of interest rates
—Improper calculations or APR disclosures
—Miscalculated fees and add-on products
—Applying complex of tiered rates structures and variable payment schedules
Carleton pointed out its newest survey data also showed a significant gap between the scale of compliance risk and the rigor of current validation practices.
The survey found only 10% of organizations validate their calculations in a systematic, automated manner. The majority — 56% to be exact — rely on manual or only partial checks.
Carleton feared that the practice by the majority is “leaving them exposed to pattern-of-practice violations that regulators specifically target.”
The service provider backed its reasoning by stating this gap is reflected directly in confidence levels, as 67% of professionals surveyed said they are not confident or only slightly confident in their organization’s ability to survive a multi-state examination today.
“The operational burden is profound,” Carleton said. “With state-level rules varying widely and changing frequently, organizations operating across multiple jurisdictions face compounding complexity in keeping systems current and calculations accurate.
“Respondents pointed to the difficulty of interpreting multi-state regulatory requirements, updating and testing loan calculation logic, and coordinating changes across multiple vendors or internal systems as their top compliance challenges,” the company continued. “The cost of getting it wrong, in the form of reimbursements, audit findings, and regulatory scrutiny, is increasingly tangible.”
Looking ahead, the survey showed lenders indicated strong demand for tools that reduce errors and close compliance gaps. Top desired improvements included:
—More accurate and reliable calculation software
—Improved audit readiness and reporting
—Better real-time monitoring for compliance violations
—Stronger system integration across lending platforms.
Taken together, Carleton vice president of business development Tim Yalich said the findings reveal a sector urgently seeking greater accuracy, automation, and confidence without sacrificing operational efficiency.
“This data makes clear that the compliance challenge facing lenders today isn’t just about keeping up with regulatory changes, but also about having systems precise enough to catch errors before regulators do,” Yalich said. “When nearly three-quarters of lenders have already had to reimburse borrowers for APR miscalculations, and the majority are still relying on manual validation, the industry has a structural problem that demands a structural solution.
“Carleton exists precisely to give lenders the calculation accuracy and multi-state compliance confidence they need,” he added.
For more information about these survey results and learn more about Carleton’s compliance calculation solutions, visit www.carletoninc.com.