CFPB, Federal Agencies, State Agencies, and Attorneys General
In a September 28, 2022 blog post, the CFPB examined the potential impact of rising vehicle prices on consumers with deep subprime credit scores, concluding that they are particularly likely to be financially vulnerable.
This is the CFPB’s second blog post in a matter of weeks examining the impact of rising vehicle costs on consumers. … Continue Reading
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 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 industry. The new rules went into effect on June 24, 2018.
Under the new rules, dealers must provide a financing statement in a prescribed form prior to the execution of any retail installment contract (RIC). … Continue Reading
We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to covered members of the armed forces and their families. The text of H.R. 2697 is now available.
Titled the “Transparency in Military Lending Act of 2017,” the bill would add the following items to the list of mandatory disclosures required under the MLA:
The CFPB has announced that a summer meeting of its Consumer Advisory Board is scheduled for June 18, 2015 in Omaha, Nebraska. Director Cordray is slated to attend the meeting.
The meeting will focus on trends and themes in consumer financial markets and recent proposals related to payday loans, auto title loans, and other longer term credit products. … Continue Reading
Yesterday, I had the opportunity to participate as an advisor to a small entity representative (“SER”) at the small business review panel on payday, title and installment loans. (Jeremy Rosenblum has four posts—here, here, here and here—that analyze the rules being reviewed in detail.) The meeting was held in the Treasury Building’s Cash Room, an impressive, marble-walled room where President Grant held his inaugural reception. … Continue Reading
This is the last of a series of blog posts in which we share our reactions to the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s proposed limits on payment collection practices. (Our previous blog posts have looked at the CFPB’s grounds for the proposals, how the proposals will impact “short-term” Covered Loans, the flaws we see in the CFPB’s ability to repay analysis, and the 36% “all-in” rate trigger and restrictions for “longer-term” Covered Loans.)… Continue Reading
In this blog post, we share our thoughts on the 36% “all-in” rate trigger and restrictions for loans considered to be “longer-term” under the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). (Our previous blog posts have looked at the CFPB’s grounds for the proposals, how the proposals will impact “short-term” Covered Loans and the flaws we see in the CFPB’s ability to repay analysis.)… Continue Reading
In this blog post, we share our thoughts on how the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”) will impact “short-term” Covered Loans and the flaws we see in the CFPB’s ability to repay analysis. (Our last blog post looked at the CFPB’s grounds for the proposals.)… Continue Reading
Last Friday, we posted a summary of the contemplated CFPB proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s grounds for the proposals. Over the next few days, we will be publishing several additional blog posts to share our reactions to the proposals’ details.… Continue Reading
