In June 2013, Morrison & Foerster published the client alert “CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars.”
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, in the intervening period we have reflected at greater length on the Bulletin and its implications in the fair lending arena. In our view, financial institutions of all stripes that are subject to CFPB jurisdiction—and even those that are not—are well advised to study closely the Bulletin and its implications for CFPB fair lending compliance and enforcement activities across the regulatory spectrum, because the Bulletin raises several notable—and potentially troubling—compliance and liability issues.
Click here to read the full alert.