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Consumer Financial Protection Bureau (CFPB) Retail Installment Sales Contracts

Troutman Pepper

Loans, Retail Installment Contracts, and Refinancing Programs — Moving the Metal: The Auto Finance Podcast

Troutman Pepper on

In this episode, Brooke Conkle and Chris Capurso delve into the topic of refinancing and its impacts on the auto finance industry. They are joined by special guest Jason Cover, who provides insights and education on retail...more

Ballard Spahr LLP

FTC requests comment on consumer advocate petition regarding auto “yo-yo financing”

Ballard Spahr LLP on

On May 31, 2023, the Federal Trade Commission (“FTC”) requested public comment on a petition for rulemaking it received from six national consumer advocate groups regarding “yo-yo sales,” a term the groups use to refer to...more

Sheppard Mullin Richter & Hampton LLP

CFPB’s Latest Orders Place Data Practices Front and Center for 2022

Last month, the CFPB utilized its market monitoring authority to issue a series of orders to five companies offering “buy now, pay later” credit. Buy now, pay later, or BNPL, is a deferred payment option that allows consumers...more

Ballard Spahr LLP

CFPB issues consent order against auto finance company regarding interest charged on late payment of loss damage waiver fee

Ballard Spahr LLP on

The CFPB recently issued a consent order against 3rd Generation, Inc., doing business as California Auto Finance (California Auto), regarding interest charged on consumers’ late payment of the fee charged for California...more

Ballard Spahr LLP

Report from SBREFA Panel on Payday, Title and Installment Loans

Ballard Spahr LLP on

Wednesday, I had the opportunity to participate as an advisor to a small entity representative (“SER”) at the small business review panel on payday, title and installment loans. The meeting was held in the Treasury Building’s...more

Ballard Spahr LLP

AFSA vehicle sales finance study finds significant flaws in CFPB disparate impact methodology and approach

Ballard Spahr LLP on

A study of indirect auto financing commissioned by the American Financial Services Association found that the CFPB’s proxy methodology for measuring disparities in auto dealer reserve is “conceptually flawed in its...more

Ballard Spahr LLP

The CFPB Stretches ECOA Past the Breaking Point with Auto Finance

Ballard Spahr LLP on

In a story released last night, Carter Dougherty at Bloomberg reports that the CFPB has warned “at least four banks” that it may take enforcement action against them under ECOA, alleging that a “policy” of “allowing” dealers...more

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