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Is Different Pricing for Non-Credit Products and Services Illegal Discrimination? Yes, Says the CFPB, Massachusetts, and the FTC

The Consumer Financial Protection Bureau made news this year when it announced that it considered discrimination to be illegal as an "unfair" practice, including in situations where fair lending laws do not apply. In March,...more

CFPB, The Roadmap Forward - Part Three

Part Three: Risk Reward Will Always be Part of the Subprime Future - We resume our conversation where we left off on Part Two with a question citing the Taskforce report with recommendations for improved financial...more

Navigating the Minefields When Offering a Credit Customer the "Lowest Rate"

Every day, financing providers offer financing to customers. Sometimes they encourage a customer to apply for credit with the dealer by saying that they can offer the customer the best financing deal. Such a claim got a Ford...more

CFPB, The Roadmap Forward - Part One

This article is the first of an exclusive three-part series interview with Jean Noonan, member of the CFPB Taskforce on Federal Consumer Law. In January 2020, the Consumer Financial Protection Bureau (CFPB) appointed a...more

Assessing Disparate Impact in the Days of COVID-19

The novel coronavirus upended American lives, changing how we work, how we socialize, how we shop, and - for millions of us - whether we are still employed. For many creditors, it also changed patterns of consumer default. In...more

Fixing Mistaken Repos

Your company gets an irate call from a customer whose car you have just repossessed for non-payment. The caller is furious because he made a payment that was supposed to prevent a repossession. After you confirm the payment,...more

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