Christopher J. Willis

Christopher J. Willis

Ballard Spahr LLP

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CFPB Finalizes Rule to Supervise Nonbank Auto Finance Companies, Releases Auto Finance Examination Procedures for Banks, Nonbanks

The Consumer Financial Protection Bureau has issued a final rule allowing it to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Relatedly, it adopted simultaneously a...more

6/12/2015 - Auto Lease Automotive Industry Automotive Loans Car Dealerships CFPB Consumer Financial Products Consumer Lenders Final Rules Market Participants Nonbank Firms

‘Operation Ruse Control’ Announcement Highlights Importance of Auto Finance Compliance

The Federal Trade Commission—and numerous other federal, state, and local law enforcement agencies in the United States and Canada—recently announced that an enforcement initiative dubbed “Operation Ruse Control” has resulted...more

4/1/2015 - Automotive Industry Automotive Loans Car Dealerships Consumer Financial Products Consumer Lenders Enforcement Actions FTC Strategic Enforcement Plan

Feds Obtain First-Ever Settlement over Allegedly Discriminatory ‘Buy Here, Pay Here’ Car Dealership Financing

The U.S. Department of Justice (DOJ) and the North Carolina Department of Justice recently requested court approval of a consent decree arising out of alleged racial discrimination by two North Carolina car dealerships in...more

2/16/2015 - Car Dealerships Discrimination DOJ Equal Access to Credit Predatory Lending Race Discrimination Racial Discrimination

Federal Trade Commission Seeks Comments on Proposed Changes to Used Car Rule

The Federal Trade Commission (FTC) recently announced that it is seeking supplemental public comments on proposed changes to its Used Motor Vehicle Trade Regulation Rule (Used Car Rule) and the Used Car Buyers Guide (Buyers...more

12/1/2014 - Automotive Industry Car Dealerships FTC Proposed Amendments Public Comment

CFPB Releases Report on Fair Credit Exams and White Paper on Proxy Methodology

Along with its proposed larger participant rule for the auto financing market, the Consumer Financial Protection Bureau issued a special edition of Supervisory Highlights (the "report") describing its fair credit supervisory...more

9/24/2014 - Automotive Industry Automotive Loans Car Dealerships CFPB Debt Buyers Larger Participant

Justice Department, U.S. Attorney, N.C. Attorney General Sue over Reverse Redlining by Auto Dealers

The U.S. Department of Justice (DOJ), the U.S. Attorney’s Office, and the North Carolina Attorney General filed a complaint last week against two corporations that own two “buy here, pay here” used car dealerships, as well as...more

1/21/2014 - Car Dealerships DOJ ECOA Unfair or Deceptive Trade Practices

DOJ Settles Fair Lending Case against Auto Dealer

The U.S. Department of Justice (DOJ) recently settled a fair lending lawsuit against Union Auto Sales, Inc., a California automobile dealer. This means that, once again, a DOJ attempt to use disparate impact evidence to...more

9/24/2013 - Car Dealerships Discrimination Disparate Impact DOJ Fair Lending Settlement

Auto finance: can we really call disparate impact “discrimination”?

I want to thank Jeff Sovern over at the Public Citizen Consumer Law & Policy Blog for having an interesting back-and-forth with me over the last week about the application of the disparate impact theory of liability to dealer...more

4/1/2013 - Automotive Industry Car Dealerships CFPB Discrimination Disparate Impact ECOA Fair Lending

How the CFPB’s stance on ECOA in auto finance will raise consumer prices

Ever since the CFPB’s release of its bulletin relating to disparate impact analysis of dealer rate participation last week, the press and consumer advocacy groups have been buzzing about the Bureau’s stance and its potential...more

3/28/2013 - Automotive Industry Car Dealerships CFPB Disparate Impact ECOA Financing

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

The CFPB previews its coming auto finance fair lending enforcement actions

Earlier today, the CFPB released its guidance bulletin with respect to automobile indirect finance fair lending issues. The bulletin’s intent is unmistakably clear from the accompanying press release’s tag line: “CONSUMER...more

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

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