What's the Dilly-o with auto & indirect: a buyer's guide for credit unions
Point Predictive estimates that credit unions have lost about $1.2 billion to auto lending fraud since 2022.1
The Dilly-o
NCUA says it has seen "seemingly healthy credit unions fail in a matter of months" because indirect programs spun out of control.2 Its guidance says fraud prevention and detection should be part of the credit union's oversight program.3 Pick a platform that lets you set the dealer rules, catch bad documents before funding, and report results dealer by dealer.
How we'd size up a vendor
- Dealer oversight - can the platform show you each dealer's loan quality, lien status and proof of insurance in one place? Ask to see how a single problem dealer would show up before it becomes a portfolio problem.
- Fair lending - does the system record dealer markup and pricing on every deal so you can test it for disparities? You want that data in a form your compliance team can pull without a custom project.
- Fraud checks - how does the vendor validate identity, income and deal documents before you fund the loan? Ask what it catches automatically and what still lands on your funders' desks.
- Exit terms - what would it cost your credit union to leave, and which termination and default terms will the vendor negotiate?
What changed this year
CU Today reported credit union auto delinquency at 90 basis points in the third quarter of 2024, up 11 basis points over that year.4 The rate stood at 96 basis points in the fourth quarter of 2025, about where it was a year earlier.5 After the collapse of auto lender Tricolor, losses at community and regional banks ranged from $22 million at Renasant to $200 million at Fifth Third.6
Will it work with your systems?
Origence says credit unions on its CUDL network can use the indirect module of its arc OS origination system or connect an existing loan origination system (LOS).7 Fuse Finance offers a dealer and merchant portal, and it is listed on Jack Henry's Fintech Integration Network for Symitar credit unions under lending and deposits.C Ask your provider which LOS and core it boards indirect loans into today, and ask for a credit union on your core that you can call.
What other credit unions did
On Dec. 10, 2024, Coastal Credit Union and Truliant Federal Credit Union partnered with TrueBuy Automotive to create Credit Union Auto Marketplace, a used-car buying experience for members.8 A California's Credit Unions article describes a lending team that uses automation to identify and sort over 100 document types used in indirect auto lending.9
What your examiner will ask
NCUA made auto lending, and indirect programs in particular, a top supervisory priority for 2024 exams.10 Its indirect lending guidance expects quality control to confirm perfected liens, proof of insurance and accurate deals.3 It also expects internal audit to test each dealer's loans through direct member contact.3 And it calls for static loan pool results compiled for each vendor and for the overall program.3 For 2024, NCUA said it would run fair lending exams at certain federal credit unions.1112 Expectations under the Equal Credit Opportunity Act (ECOA) and Regulation B are unchanged.1312 Credit unions should run ongoing analysis of indirect pricing data for prohibited disparities.1312
What it costs
Most indirect platforms do not publish their pricing, so expect to get a quote. A CRIF case study on a $210 million credit union cites a funding fee of up to $199 per funded loan.14 Open Lending reports average program fee revenue of $538 per certified loan in the first quarter of 2026, down from $550 a year earlier.15 Time to implement is not public either, so ask for dates from a recent client on your core. NCUA warns that some credit unions accepted large buyout or termination penalties believing them fixed, though early termination, escape and default terms are often negotiable.16
Food for thought
We'd give document checks the closest look in any indirect demo, since that is where you can test a vendor's fraud claims. We'd ask every vendor how its checks will keep up over the next two years, and write that answer into the contract.
Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work
Sources
- Credit union losses tied to auto fraud reach $1.2B - Auto Finance Newswww.autofinancenews.net
Credit unions have lost an estimated $1.2 billion tied to auto lending fraud since 2022, according to Point Predictive.
- Indirect Lending and Appropriate Due Diligencencua.gov
NCUA has seen seemingly healthy credit unions fail in a matter of months due to indirect lending programs that spun out of control.
- Indirect Lending and Appropriate Due Diligencencua.gov
- Quality control processes to ensure the credit union receives perfected liens, proof of insurance, and other necessary documentation, in addition to...
- CU Loan Growth ‘Anemic,’ Delinquencies Rising / THE feature / CUToday.info - CU Todaywww.cutoday.info
- The auto loan delinquency rate increased 11 basis points over the year to 90 basis points in the third quarter of 2024.
- National Credit Union Administration Quarterly Credit Union Data Summaryncua.gov
• The **auto loan** delinquency rate was 96 basis points in the fourth quarter of 2025, essentially unchanged from a year earlier.
- Dimon on auto lender Tricolor collapse: 'Not our finest moment'www.americanbanker.com
For some of the community and regional banks, the losses were more material, ranging from $22 million at Renasant to $200 million at Fifth Third.
- CUDL for credit unionsorigence.com
With CUDL^®, you’ll have access to the indirect lending module of our loan and account origination system, arc OS™ indirect, or you can integrate with...
- Coastal and Truliant Credit Unions Partner to Launch Credit Union Auto Marketplacewww.finopotamus.com
“Being able to enhance our members’ experience by saving them time and money in their search deepens our ... # Coastal and Truliant Credit Unions Par...
- Growing Indirect Lending Efficiencies With AI - California's Credit Unions and Nevada's Credit Unionswww.californiascreditunions.org
- **$210,000 in annual savings:** The team now handles the same loan volume with fewer full-time employees—down from 6.4 to 2.8.
- Auto Loan Troubles Mount as Indirect Lending Hits a Snag - United Creditors Connectwww.unitedcreditorsconnect.com
Regulators took notice: the NCUA made auto lending (especially indirect programs) a top supervisory priority for 2024 examinations.
- A Closer Look at NCUA's Consumer Financial Protection and Compliance Expectationswww.consumerfinancialserviceslawmonitor.com
However, this does not preclude NCUA examiners from reviewing indirect auto lending for ... # A Closer Look at NCUA’s Consumer Financial Protection a...
- A Closer Look at NCUA's Consumer Financial Protection and Compliance Expectationswww.consumerfinancialserviceslawmonitor.com
- Credit unions should conduct regular analyses of indirect loan pricing data for potential disparities on a prohibited basis.
- CFPB Authority Over Auto Finance — What the Bureau Can and Cannot Reach - Car Real Talkcarrealtalk.com
But **ECOA and Regulation B (12 CFR § 1002) remain unchanged**, so the underlying fair lending expectations continue to shape supervisory examinations...
- How a $210M Credit Union rebuilt its auto portfolio with indirect lending - Indirect Lending, Dealer Management & Digital Solutionswww.crif.us
"* Canopy charges a funding fee of up to $199 per funded loan, one of the few credit unions in its market to do so.
- Open Lending Reports First Quarter 2026 Financial Resultsinvestors.openlending.com
- Average program fee revenue per certified loan was $538 in the first quarter of 2026, compared to $550 in the first quarter of 2025.
- Evaluating Third Party Relationshipsncua.gov
For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...