Auto finance companies and others in the auto space should take note of a recent joint letter issued by the Consumer Financial Protection Bureau (CFPB) and Department of Justice (DOJ) about the legal protections under the Servicemembers Civil Relief Act (SCRA). In the letter, CFPB Director Rohit Chopra set out that “[t]he CFPB is closely
In an action somewhat lost amidst the unprecedented $2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Federal Reserve’s Board of Governors announced a series of five “extensive new measures” to provide liquidity for certain sectors of the nation’s economy. One of those liquidity facilities, the reintroduced Term Asset-Backed Securities Loan Facility
The Consumer Financial Protection Bureau made it clear that it will continue to target auto finance lenders as one of its top supervisory and enforcement priorities in the Fair Lending Report of the Bureau of Consumer Financial Protection , which was released in June 2019. In addition to adding student loan origination to its watchdog
In 2013, the Consumer Financial Protection Bureau (CFPB) issued a bulletin on indirect auto lending that took the industry by storm. As we approach the five-year anniversary of the memo’s issuance, it’s valuable to reflect on how the bulletin was received, how the auto finance industry has changed since the bulletin and subsequent CFPB actions,
Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants was that the Trump administration would bring loosened regulation for the consumer finance industry. Many industry insiders mused about the potential sea change that
The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and payment restrictions on certain covered loans. Be sure to review our previous blog post “CFPB Releases Long Awaited Small Dollar Rule: 5 Things
Should a full-service consumer finance company be subject to federal debt collection law when it attempts to collect upon debt it purchased? Attorneys general from Maryland, the District of Columbia, California, New York, and more than two dozen other states have urged the Supreme Court to adopt a startling new interpretation of federal law and
The Supreme Court’s most recent citizenship opinion, Americold Realty Trust v. Conagra Foods, Inc., could make removing or keeping a case in federal court based on diversity more difficult for a statutory trust with a proprietary or complex ownership structure.
With Americold, the Supreme Court clarified a circuit split regarding the citizenship of