Warning Signs on the Road for Auto Lenders

The warning signs are evident: a growing reliance on new, unproven loan products; a sharp spike in early delinquencies; and the collapse of a few smaller subprime lenders. Is auto lending in 2018 beginning to resemble the housing market circa 2008? Perhaps, but there are important differences. The economy is stronger than it was 10 […]
  • Matt Isaacson
  • November 28, 2018
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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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Military Lending Act Continues to Plague Auto Finance Industry

Since the Department of Defense released its amended interpretive rule in December 2017, the Military Lending Act (MLA) has been a source of much confusion and consternation for the auto finance industry. Before that time, most of the industry operated under the understanding that the MLA’s exclusion from coverage for consumer credit transactions “expressly intended […]
  • Patricia Covington and Erica Kramer
  • October 19, 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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FTC Conducts First Compliance Sweep Since Amendment to Used Car Rule

The Federal Trade Commission (FTC) announced in mid-July that it conducted the first compliance sweep of car dealerships since the effective date of its revised Used Car Rule requiring the use of a new Buyer’s Guide sticker. The sweep occurred between April and June 2018 in 20 cities nationwide. The FTC partnered with 12 agencies […]
  • Chad Fuller
  • September 7, 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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Auto Finance Excellence Relaunches as a New Community for Industry Professionals

Auto Finance Excellence today relaunched as a comprehensive online community and industry resource for best practices and advice for auto lending and leasing professionals. At the new Auto Finance Excellence (www.autofinanceexcellence.org), formerly known as the Center for Auto Finance Excellence industry executives will find insights, ideas, and innovation on the practice of auto finance. The […]
  • Nicole Casperson
  • August 6, 2018
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Ten Years Later: CFPB, the Financial Crisis, What Have We Learned?

I know it’s hard to put an exact date at the beginning of the financial crisis but think most “scholars” would agree things started going south rapidly in the Fall of 2008. A celebratory feeling at this approximately 10-year anniversary mark is likely a stretch, but it’s worth acknowledging what happened, how to prevent or […]
  • Samuel Ellis
  • July 30, 2018
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