CFPB Continues Focus on UDAAP

There is a continued focus by the Consumer Financial Protection Bureau on acts or practices deemed unfair, deceptive, or abusive — commonly called “UDAAP.” Following is a summary overview of UDAAP and an analysis of a recent argument made by the CFPB in this area: Unfair acts or practices are divided into three prongs. An […]
  • Courtney Gilmer
  • November 20, 2017
  • 0

4 Tips for Setting Up Your CMS for Compliance Success

LAS VEGAS — Compliance is a necessary but logy topic that all lenders and dealers must comply with, and having a proficient compliance management system (CMS) has — by virtue of its association with compliance — also become a de facto necessity. For Veros Credit, it took two years of building out its in-house CMS […]
  • Emma Sandler
  • November 9, 2017
  • 2

Approvals Rise as Funding Rates Worsen, Exclusive Survey Reveals

Although overall approval rates are higher this year, application funding rates for subprime credit have fallen, according to a recent best practices survey conducted by The Center for Auto Finance Excellence. Meanwhile, delinquency and loss rates have worsened — particularly on subprime — and lenders are still spending more, specifically on technology and compliance. The […]
  • Natalie Mattila
  • November 1, 2017
  • 1

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
  • 0

Best Practices Survey: We Want to Hear From You

Today is the last day to participate in the Center for Auto Finance Excellence’s best practices survey — and to be entered into a drawing to win a a $50 Amazon gift card. The Center is constantly working to enhance its relevance and service to you and the industry. As an important part of the auto finance community, we are […]
  • Natalie Mattila
  • October 3, 2017
  • 0

Best Practices Survey: We Want to Hear From You

The Center for Auto Finance Excellence is constantly working to enhance its relevance and service to you and the industry. As an important part of the auto finance community, we are coming to our members for best practice insights.Please take a moment to complete this short survey, which will offer valuable benchmark data to the industry. […]
  • Natalie Mattila
  • September 19, 2017
  • 0

Compliance Insider: The Cynic Returns

You may recall that last month I wrote about how a cynic might view the Consumer Financial Protection Bureau’s arbitration rule and its corresponding ban on class-action waivers in predispute arbitration agreements. My cynic held the view that the rule, while purporting to be only a ban on waivers, was really just a back-door attempt […]
  • Michael Benoit
  • September 15, 2017
  • 0

Why Regulators Are Keeping a Close Watch on Dealers

Dealers are faced with an assortment of issues today when it comes to the red-tape of compliance. From the Consumer Financial Protection Bureau to the Department of Justice and state attorneys general, they are all keeping a close watch on dealer business practices. But some issues, more than others, are worrying both independent and franchise […]
  • Emma Sandler
  • September 13, 2017
  • 0

The Cynic’s View on the CFPB Arbitration Rule

On July 10, the Consumer Financial Protection Bureau issued the final version of its arbitration rule banning consumer financial services providers from enforcing federal or state court class-action waivers in pre-dispute arbitration agreements. The rule — which takes effect Sept. 19 and with which compliance will be required in March 2018 — does not prohibit […]
  • Michael Benoit
  • September 5, 2017
  • 0
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