Is it time to "tune up" your compliance with the Fair Credit Reporting Act ("FCRA")?

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In September 2021, the FTC approved technical changes to five regulations implementing the Fair Credit Reporting Act.

Under the Dodd-Frank Act, the CFPB may not exercise any rulemaking, supervisory, enforcement or any other authority, including any authority to order assessments, over a motor vehicle dealer that is predominantly engaged in the sale and servicing of motor vehicles, the leasing and servicing of motor vehicles, or both. However, the CFPB maintains authority over a motor vehicle dealer (i) providing extension of retail credit or retail leases directly to consumers and not routinely assigning such contracts to an unaffiliated third party finance or leasing source; or (ii) offering or providing a consumer financial product or service not involving or related to the sale, financing, leasing, rental, repair, refurbishment, maintenance, or other servicing of motor vehicles, motor vehicle parts, or any related or ancillary product or service.

Originally published in Tennessee Dealer News, Fall 2021.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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