Investigation Tag Team: The FTC and the State of Arizona — Moving the Metal: The Auto Finance Podcast
The FTC and Connecticut Join Forces for Action Against Nissan Dealer
The CARS Rule — Moving the Metal: The Auto Finance Podcast
Avoiding Auto Finance Pitfalls Under the FTC's New CARS Rule — The Consumer Finance Podcast
Preventing and Detecting Fraud: How to Protect Your Dealership
Podcast: Buy-Sell Market - Factors to Consider in Transactions of Automotive Dealerships
AFSA Extra Credit Podcast: Auto Remote Sales Compliance
AF COVID-19 Podcast: Online Auto Sales in the Age of COVID-19
AF COVID-19 PODCAST: Auto Dealers & Stay at Home Orders
II-31- The Changing 9 to 5 From 1980 to Today
Polsinelli Podcasts - Removing Caps on Punitive Damages: What is the Impact on Business?
In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC's proposed CARS Rule. After a refresher on the rule's requirements, Brooke and...more
In this month's article, we share some of our top "bites" for the prior month covered during the December 2023 webinar....more
We all know that discrimination violates various federal and state laws, but the FTC has been insisting for a while now that it also violates Section 5. A recent joint complaint the agency brought with the State of Wisconsin...more
On May 2, the CFPB published a blog post demonstrating its commitment to “a fair, transparent, and competitive auto lending market” by calling attention to add-on products for which auto dealers and finance companies “often...more
Players in the auto finance industry have been watching the Consumer Financial Protection Bureau ping-pong over the last several years regarding disparate impact theories under the Equal Credit Opportunity Act. The disparate...more
So, the general consensus is that a Biden/Harris Administration will mean lots of change for automotive finance. But, exactly what types of change and how quickly will that change occur? And, just how bad for the industry...more
The FTC recently announced a settlement of its lawsuit filed in a New York federal district court against a New York City car dealership and its individual general manager in which the FTC alleged that the defendants...more
Two recent events got me thinking. The first was a new car purchase. Finally persuaded that the newer cars had safety features that were truly life-saving and accident-reducing, my wife and I opted to replace the old bus...more
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...more
If you’ve followed the status of the CFPB’s enforcement actions under the Equal Credit Opportunity Act related to auto dealer finance charge participation, you probably would have concluded that those cases are unlikely to...more
The New York City Department of Consumer Affairs (DCA) has adopted new rules for used car dealers, requiring all licensed dealers to make additional disclosures to consumers and creating a new consumer bill of rights for the...more
With the stroke of a pen, President Trump nullified the 2013 informal guidance on “Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act” (Guidance) issued by the Consumer Financial Protection Bureau...more
One month after the U.S. Senate and U.S. House of Representatives voted to repeal of the Consumer Financial Protection Bureau’s (CFPB’s) indirect auto lending guidance under a Congressional Review Act challenge, President...more
Yesterday afternoon, President Trump signed into law S.J. Res. 57, the joint resolution under the Congressional Review Act (CRA) that disapproves the CFPB’s Bulletin 2013-2 regarding “Indirect Auto Lending and Compliance with...more
We previously reported that Congress might have the opportunity to disapprove the CFPB’s disparate impact theory of assignee liability for so-called auto dealer “markup” disparities because the CFPB Bulletin describing its...more
On April 18, the Senate voted to repeal the Consumer Financial Protection Bureau's (CFPB) 2013 Guidance on Fair Lending Practices to Indirect Auto Lenders (2013 Guidance) using the Congressional Review Act (CRA). The vote was...more
The New York City Department of Consumer Affairs (DCA) has proposed new rules for used car dealers that would require dealers to provide the following disclosures to buyers...more
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...more
As we reported recently, the Government Accountability Office has determined that CFPB Bulletin 2013-02 on dealer pricing in indirect auto finance (“Dealer Pricing Bulletin” or “Bulletin”) is a “rule” subject to review under...more
The Federal Trade Commission (FTC) has filed an action against nine auto dealerships and their individual owners in a California federal court that the FTC described as its "first action against an auto dealer for 'yo-yo'...more
A recent Federal Trade Commission (FTC) consent order with two Ohio auto dealers creates uncertainty not only for auto dealers, but also for all other businesses advertising credit or lease offers. The order settled...more
On June 10, 2015, the Consumer Financial Protection Bureau (CFPB) announced a final rule that will allow it to supervise larger nonbank automobile finance companies. Accompanying the rule, it also published the procedures...more
The Consumer Financial Protection Bureau has issued a final rule allowing it to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Relatedly, it adopted simultaneously a...more
The Federal Trade Commission—and numerous other federal, state, and local law enforcement agencies in the United States and Canada—recently announced that an enforcement initiative dubbed “Operation Ruse Control” has resulted...more