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MoFo Reenforcement The Enforcement Blog

Tag Archives: Indirect Auto Lending

House Votes to Nix Indirect Auto Bulletin and Expand QM

Posted in CFPB, Fair Lending, Indirect Auto Lending, Mortgage

The U.S. House of Representatives passed legislation on November 18, 2015, that would revoke the CFPB’s guidance on indirect auto lending and expand the qualified mortgage rule’s safe harbor. The Reforming CFPB Indirect Auto Financing Guidance Act, H.R. 1737, “[d]eclares without force or effect” the CFPB’s Bulletin 2013-02 (Indirect Auto Lending and Compliance with the… Read More

#ThrowbackThursday: CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars

Posted in CFPB, Fair Lending, Indirect Auto Lending

In June 2013, Morrison & Foerster published the client alert “CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars.” Summary: Several weeks ago, the CFPB issued a fair lending guidance bulletin (“Bulletin”) directed at financial institutions that make indirect automobile loans. While the Bulletin thus far has not attracted widespread public attention,… Read More

CFPB Orders Auto Financer to Pay $48.3M for Misleading Borrowers

Posted in CFPB, Enforcement Actions, Indirect Auto Lending, UDAAP

On September 30, 2015, the CFPB ordered an indirect auto lending company and its auto lending subsidiary to pay $48.3 million in fines for alleged FDCPA, TILA, and UDAAP violations. The CFPB alleges that the companies manipulated borrowers by using phony caller ID information and lying about imminent repossession or criminal charges in order to… Read More

CFPB Supervisory Highlights Report on Indirect Auto Lending

Posted in Auto Lending, CFPB

On September 17, 2014, the CFPB issued a supervisory highlights report concerning discriminatory practices in automobile lending. The report focused on so-called “indirect auto lending” which the CFPB defines as “when a consumer secures vehicle financing through the dealer, which typically originates the loan to the consumer and arranges financing through a third-party financial institution.”… Read More