Following up on a threat it made back in 2018, the New York State Department of Financial Services (DFS) announced on October 6, 2022 that it entered into a consent order with Rhinebeck Bank (“Rhinebeck”) to settle discrimination claims involving discretionary dealer markups on retail installment contracts with minority borrowers. Under the settlement, Rhinebeck will pay a $950,000 civil money penalty, provide restitution to borrowers, and develop a compliance plan which includes updates to its auto policies to cap dealer markups on installment contracts purchased by the bank.… Continue Reading
auto lending
CFPB June 2016 complaint report highlights consumer loan complaints, complaints from Arkansas consumers
The CFPB has issued its June 2016 complaint report which highlights complaints about consumer loans and complaints from consumers in Arkansas and the Little Rock metro area. The CFPB began taking consumer loan complaints in March 2012. The consumer loan category in the CFPB’s consumer complaint database includes complaints about auto loans and leases, installment loans, personal lines of credit, title loans, and pawn loans. … Continue Reading
The CFPB Stretches ECOA Past the Breaking Point with Auto Finance
In a story released last night, Carter Dougherty at Bloomberg reports that the CFPB has warned “at least four banks” that it may take enforcement action against them under ECOA, alleging that a “policy” of “allowing” dealers to negotiate contract APRs with retail buyers had a disparate impact in the pricing of retail installment sale contracts purchased by the banks. … Continue Reading