In This Issue:
- Beltway Report
- Bureau Report
- Mobile & Emerging Payments Report
- Mortgage & Fair Lending Report
- Operations Report
- Preemption Report
- Privacy Report
- Arbitration Report
- TCPA Report
- Excerpt from Beltway Report:
Ain’t No Party Like a FIRREA Party -
Recent SEC filings from a number of financial institutions indicate DOJ is looking to apply FIRREA to the world of automobile lending. According to these recent filings, DOJ is interested in subprime auto lending origination and securitization (sounds eerily familiar to anyone involved in the recent mortgage matters). FIRREA is the current statute of choice for DOJ because it provides for a less stringent burden of proof than traditional fraud and the imposition of significant civil money penalties. It remains to be seen how these investigations will play out and how broadly the DOJ will cast its net.
Please see full alert below for more information.