Alan S. Kaplinsky

Alan S. Kaplinsky

Ballard Spahr LLP

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House Democrats request auto fair lending information from the CFPB

We have previously blogged about the CFPB’s laser-like focus on the fair lending practices of banks and non-banks purchasing auto finance consumer contracts from auto dealers....more

6/3/2013 - Automotive Industry CFPB ECOA Financing Loans

CFPB delays effective date of Reg Z prohibition on financing credit insurance premiums

The CFPB has issued a final rule delaying the June 1, 2013 effective date of the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)). The final rule sets January 10, 2014 as the prohibition’s...more

5/30/2013 - CFPB Financing Insurers Mortgages Premiums Regulation Z TILA

Auto dealer trade groups question CFPB guidance

It seems two major auto dealer trade groups share my doubts about whether the CFPB’s position on dealer rate participation will really help car buyers. In a statement responding to CFPB Bulletin 2013-02, the National...more

3/25/2013 - Car Dealerships CFPB Financing FTC

CFPB Issues Guidance on Indirect Auto Lending ECOA Compliance

The Consumer Financial Protection Bureau has issued guidance on fair lending compliance for indirect auto lenders. The guidance targets the practice of “dealer markups.” This practice involves an auto dealer charging the...more

3/22/2013 - Automotive Industry Car Dealerships CFPB Compliance ECOA Fair Lending Financing

So this is what the CFPB means about leveling the playing field?

My colleague, Chris Willis, posted his reaction to CFPB Bulletin 2013-02, which provides guidance as to how the CFPB will apply ECOA and Reg B to dealer rate participation in the auto finance business. Except for Chris’...more

3/22/2013 - Automotive Industry Business Justification Car Dealerships CFPB ECOA Financing Regulation B

CFPB lawyer discusses disparate impact in auto financing and says important development to happen soon

At the ABA Consumer Financial Services Committee meeting earlier this week, Rick Hackett, Assistant Director of the Research, Markets and Regulations Division of the CFPB, spoke about “Discretionary Pricing in Indirect Auto...more

1/10/2013 - Automotive Industry CFPB Financing FTC

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