Unraveling the Legal Threads: A Deep Dive Into Earned Wage Access - Payments Pros: The Payments Law Podcast
Troutman Pepper Attorneys Update Fair Lending Handbook for the American Association of Bank Directors - The Consumer Finance Podcast
Consumer Finance Podcast Monitor Episode: The Consumer Financial Protection Bureau’s Final Section 1071 Rule on Small Business Data Collection: What You Need to Know, Part II, Guest David Skanderson
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
Illinois Federal Court Dismisses CFPB's First Redlining Case, Holding ECOA Doesn't Extend to Prospective Applicants - The Consumer Finance Podcast
FTC Consent Order With Auto Dealer and Proposed Rule - The Consumer Finance Podcast
Last week, the Federal Trade Commission (FTC) and the State of Arizona announced a joint action against Coulter Motor Company, an Arizona-based motor vehicle dealership, and its former general manager, for allegedly engaging...more
The Department of Justice recently announced that it had settled a lawsuit filed in 2019 that alleged a Maryland used car dealership discriminated against African Americans in violation of the Equal Credit Opportunity Act by...more
If you’ve followed the status of the CFPB’s enforcement actions under the Equal Credit Opportunity Act related to auto dealer finance charge participation, you probably would have concluded that those cases are unlikely to...more
The FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. The FTC has authority to enforce the ECOA and Reg B as to...more
As of now, the Equal Credit Opportunity Act (ECOA) prohibits dealers from unintentional, or “disparate impact,” discrimination in setting dealer reserves in auto financing. This disparate impact can result from policies or...more
To resolve charges by the Consumer Federal Protection Bureau (CFPB) and the Department of Justice (DOJ) that it engaged in unlawful discrimination in violation of the Equal Credit Opportunity Act (ECOA), American Honda...more
Large auto-lenders may soon have to contend with a new regulator. In its most recent semi-annual report, the Consumer Financial Protection Bureau (“CFPB”) highlighted its intent to promulgate a new rule which would subject...more
In March 2013, the U.S. Consumer Finance Protection Bureau (“CFPB”) announced that it would closely scrutinize dealer reserve (“markup”) practices. The federal concern is that dealer markups may result in an illegal disparate...more
On August 2, 2013, the CFPB responded to the June 20, 2013 letter from 35 Republican members of the U.S. House of Representatives, questioning the manner in which the CFPB developed recent guidance regarding indirect auto...more
Several weeks ago, the Consumer Financial Protection Bureau (“CFPB”) issued a fair lending guidance bulletin (“Bulletin”) directed at financial institutions that make indirect automobile loans. While the Bulletin thus far has...more
The Consumer Finance Protection Bureau continues to spread its wings in the enforcement arena. It is an agency born and confined in political controversy. ...more
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
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
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