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

At the ABA Consumer Financial Services Committee meeting earlier this week, Rick Hackett, Assistant Director of the Research, Markets and Regulations Division of the CFPB, spoke about “Discretionary Pricing in Indirect Auto Finance.” Rick made it very clear that the CFPB is sticking to its position that the disparate impact theory applies under the Equal Credit Opportunity Act.… Continue Reading

As we reported, apparently unbeknownst to Director Cordray, the CFPB began taking complaints about student loans and vehicle and other consumer loans on March 1. While announcing the opening of its student loan system on the home page of its website, the CFPB’s first mention of the launch of its complaint system for vehicle and other consumer loans appears to be an item posted on March 12 on the CFPB’s blog.… Continue Reading

In a blog post appearing today on the CFPB’s newly redesigned website, Director Cordray announced that the CFPB is now taking on-line complaints about deposit accounts. According to Director Cordray’s blog post (and the CFPB’s press release about the expansion), the only other complaints currently being taken by the CFPB are credit card and mortgage loan complaints.… Continue Reading