Earlier this month, the Office of Servicemember Affairs (OSA) released its annual report covering the Office’s activities during fiscal year 2019, which covers the period of October 1, 2018 to September 30, 2019.

Noteworthy items include:

  • Top Complaints Received from Military Consumers During FY19.  In FY19, the same overall number of complaints (34,600) were submitted as in FY18. 
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In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor vehicle and other personal property financing, and will revert back to the position it set forth in the original Q&A #2 published in the August 26, 2016 Interpretive Rule. … Continue Reading

The Justice Department announced in a March 15 press release that it has reached an agreement with property management company PRG Real Estate Management (PRG) and several related entities to settle claims that PRG violated the Servicemembers Civil Relief Act (SCRA) by obtaining evictions and money judgments against service-member tenants by filing affidavits that did not accurately reflect the tenants’ military status.… Continue Reading

On March 6, 2019, a California subprime auto lender, California Auto Finance, agreed to enter into a consent order with the Justice Department related to allegations that it repossessed vehicles in violation of the Servicemembers Civil Relief Act (SCRA). Under the terms of the consent order, which is still subject to court approval, California Auto Finance must pay $50,000 in civil penalties to the government and $30,000 in compensation to one individual servicemember – the highest amount the Department has ever recovered for one servicemember.… Continue Reading

Last week, the CFPB Ombudsman’s Office released its seventh annual report covering the Office’s activities during fiscal year 2018. The Ombudsman’s Office is intended to serve as an independent, impartial, and confidential resource that assists consumers, financial entities, consumer or trade groups, and others in informally resolving process issues with the CFPB.… Continue Reading

On September 19, 2018, California enacted AB-3212.  The Bill amends the California Military and Veterans Code to expand the protections offered to qualifying servicemembers under state law and to impose new criminal penalties for certain violations of its provisions.  Some of the key changes, which go into effect January 1, 2019, are as follows:

Expanded Protections

  • Extends most protections to 120 days after military service ends (prior provision extended protections for 60 days after the end of military service).
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NPR reported last week that the Trump Administration is planning to end the current prohibition under the Military Lending Act (“MLA”) against creditors offering service members GAP insurance in connection with credit intended to finance the purchase of motor vehicles. Current interpretive guidance concerning the Department of Defense’s regulations implementing the MLA prohibits creditors from financing GAP insurance – insurance that covers the difference in the actual cash value of a motor vehicle and the balance still owed on the financing – in purchase money transactions with protected service members and their dependents.… Continue Reading

The 2018 CFPB Research Conference will take place at the Crystal Gateway Marriott Hotel in Arlington, Virginia on May 3-4, 2018.  The conference is an opportunity for researchers and policymakers to learn about recent findings from both academic and government researchers in the area of consumer finance.  Panel discussions will focus on research into household budgeting and consumption, credit and labor market dynamics, consumer beliefs surrounding mortgage lending, intervention strategies for savings, credit and repayment, credit and default topics, and price sensitivity for loan products.… Continue Reading

The United States Department of Justice announced last week that Westlake Services LLC and its subsidiary, Wilshire Consumer Capital LLC, have agreed to pay $760,788 to resolve allegations the companies violated the Servicemembers Civil Relief Act (“SCRA”) by repossessing 70 vehicles owned by SCRA-protected servicemembers without obtaining the required court orders.… Continue Reading