As we reported recently, the Government Accountability Office has determined that CFPB Bulletin 2013-02 on dealer pricing in indirect auto finance (“Dealer Pricing Bulletin” or “Bulletin”) is a “rule” subject to review under...more
12/14/2017
/ Automotive Loans ,
Banking Sector ,
Car Dealerships ,
CFPB Bulletins ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
ECOA ,
Fair Lending ,
GAO
Congress may have now have the opportunity to disapprove by a simple majority vote the CFPB’s disparate impact theory of assignee liability for so-called dealer “markup” disparities as a result of a determination by the...more
12/8/2017
/ Automotive Loans ,
Banking Sector ,
CFPB Bulletins ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Disparate Impact ,
ECOA ,
Fair Lending ,
GAO ,
Leveraged Loans
In May 2017, we blogged about press reports that the Government Accountability Office (GAO) had accepted a request from Senator Patrick Toomey for a determination concerning whether the CFPB Bulletin 2013-02, titled “Indirect...more
10/27/2017
/ Add-ons ,
Administrative Procedure Act ,
Automotive Loans ,
Banking Sector ,
CFPB Bulletins ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Lenders ,
Credit Reports ,
Debt Collection ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
GAO ,
Interagency Guidance ,
Interest Rates ,
Leveraged Lending ,
Regulation B ,
Regulatory Oversight
We have previously written about the Congressional Review Act (“CRA”), a law that establishes a procedure by which Congress can nullify a covered rule adopted by a federal agency. According to a memorandum prepared by the...more
We have previously written about the Congressional Review Act (“CRA”), which was enacted as part of the Contract with America Advancement Act of 1996. The CRA created a fast-track legislative process for Congress to nullify...more
We have previously written about the Congressional Review Act (“CRA”), a law enacted in 1996 that establishes a procedure by which Congress can nullify a covered rule adopted by a federal agency. According to a Congressional...more