Is Disparate Impact Dead?

Don’t write off disparate impact just yet. Sorry to say it, but that’s where I am on the issue. After the then Consumer Financial Protection Bureau (now Bureau of Consumer Financial Protection) announced in December 2016 that it would be turning its attention from disparate impact claims in auto finance, the auto-world rejoiced. The joy […]
  • Michael Benoit
  • October 31, 2018
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CFPB Suspends Military Supervision

Recent pronouncements from the Bureau of Consumer Financial Protection’s Acting Director Mick Mulvaney have consumer advocates up in arms over how lenders will be regulated for military compliance. Ironically, the military itself seems a little less concerned, at least with respect to the BCFP, though there are plenty of military consumer advocates wringing their hands […]
  • Michael Benoit
  • September 17, 2018
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Kathy Kraninger: CFPB Nominee or Smoke Screen?

The White House nominated Kathleen Kraninger to be the new director of the Consumer Financial Protection Bureau. Currently associate director for general government in the Office of Management and Budget (i.e., deputy to OMB and interim CFPB Director Mick Mulvaney), Kraninger was not among the names rumored to have been on the shortlist for the job […]
  • Michael Benoit
  • August 22, 2018
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Defining the Job of BCFP Director

Since I last wrote for Auto Finance Excellence, the Senate held a hearing for Kathleen Kraninger, the White House’s nominee to be the new director of the Bureau of Consumer Financial Protection. For someone as unknown as she is in the financial services community, the consensus seems to be that she held her own in […]
  • Michael Benoit
  • August 9, 2018
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It’s a New Day for the CFPB

What a difference a day — or a couple of months — makes! The Consumer Financial Protection Bureau issued its five-year strategic plan in February, and boy does it paint a picture of a kinder, gentler CFPB. Well, maybe neither kind nor gentle, but I’ll settle for an agency interested in all of its stakeholders. […]
  • Michael Benoit
  • March 22, 2018
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Examining the Defense Department’s Revised Military Lending Act

If you are in the auto finance business, you cannot possibly have missed the drama percolating around the Department of Defense’s (DoD’s) new interpretation of its own regulation’s purchase-money vehicle finance exclusion, which says transactions with GAP, credit insurance, or other credit-related ancillary products are not within said exclusion. Rather, those products are “consumer credit” […]
  • Michael Benoit
  • February 19, 2018
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3 Possible Resolutions CFPB’s Mulvaney Has for 2018

As I was thinking about the things I want to accomplish personally in the new year, I pondered what the Consumer Financial Protection Bureau’s Acting Director Mick Mulvaney might be thinking about for the direction of bureau’s activities in 2018. As such, I am suggesting three resolutions Mulvaney might consider this year. I RESOLVE THAT […]
  • Michael Benoit
  • January 10, 2018
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How Does Congress’s Action Impact the CFPB’s Ability to Prohibit Arbitration Clauses?

In a nail-biter of a session, the Senate voted late in the evening on Oct. 24, to invalidate the Consumer Financial Protection Bureau’s recently finalized arbitration rule. The vote on the joint resolution — which had passed the House earlier this year — was 51 to 50 with Vice President Mike Pence assuming the gavel […]
  • Michael Benoit
  • December 18, 2017
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Is an Effort Afoot to Improve Repo Communications?

In the September issue of the Consumer Financial Protection Bureau’s Supervisory Highlights — in which CFPB supervision staff reports on issues they are seeing in the context of examinations — the staff addresses one of the more axiomatic and frustrating realities facing creditors — trying to retract a repossession order. The difficulty stems from managing […]
  • Michael Benoit
  • October 25, 2017
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