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Auto lending is a dynamic market second only to housing in size, with nearly $900 billion in outstanding auto loan balances. Banks hold approximately a third of all auto loan balances, followed closely by captive auto lenders, credit unions and auto finance companies. Under the Dodd-Frank Act, the CFPB has the authority to supervise all depository institutions with more than $10 billion in assets. However, the Bureau has also been granted the authority to supervise “larger participants” in consumer financial markets. The CFPB exercised this authority by issuing a rulemaking proposal to extend its supervisory reach over nonbank auto lenders, such as the captives and auto finance companies. CBA is largely supportive of this effort as consumers should expect to receive the same level of protection no matter where they receive their auto loans.
- June 21, 2017On Friday, June 21, 2017, CBA and other financial trades submitted a letter to the U.S. Department of Defense (DoD) recommending changes to the Military Lending Act (MLA). Specifically, the letter requests the DoD: Clarify the exemption for purchase money loans (including vehicle purchase money loans) applies unless the borrower is receiving cash from the proceeds of the loan. Thus, purchase...April 26, 2017On Wednesday, April 26, 2017, the CFPB announced it had entered into a consent order with Security National Automotive Acceptance Company (SNAAC), which had been subject to a previous Bureau enforcement action. In the first order, the Bureau alleged the company engaged in deceptive collection practices against servicemember borrowers who had obtained loans to purchase used vehicles. These...March 22, 2017Download Whitepape r. KPMG LLP (KPMG) is pleased to announce the release of the new point-of-view document related to our Chief Compliance Officer (CCO) Survey findings , The compliance journey: Boosting the value of compliance in a changing regulatory climate . In a time of new U.S. administrative impacts to the regulatory environment, determining how to boost the value you get from your...March 15, 2017Even the more sophisticated data-driven financial services marketers are struggling to figure out how to effectively and efficiently integrate personalization into multichannel customer and prospect marketing strategies. This iteration of the Epsilon 5 & 5 is intended to trigger some contrarian thoughts and challenge your marketing status quo. In this issue, we’ll talk about personalization,...December 2, 2016Breaking: OCC Moving to Create Charters for FinTech Firms The OCC today issued a White Paper detailing plans to create special purpose charters for fintech firms and is seeking comments on the various issues raised by this initiative. We applaud the OCC for their efforts to further explore chartering, and we will provide the agency with our reactions – particularly in regard to ensuring a level...October 31, 2016On Monday, October 31, 2016, the CFPB released the 13th edition of its Supervisory Highlights . The report revealed, during the review period, recent confidential supervisory resolution resulted in restitution to over 225,000 consumers totaling approximately $11.3 million. Additionally, the CFPB stated its supervisory activities have either led to or supported two recent public enforcement...June 30, 2016On Thursday, June 30, 2016, the CFPB announced its supervisory actions uncovered alleged illegal activities in auto finance and payments resulting in approximately $24.5 million in restitution to more than 257,000 consumers within the first four months of 2016. The report also highlighted issues CFPB examiners found through the agency’s examination of businesses in auto loan origination, debt...June 28, 2016On Tuesday, June, 28, 2016, the CFPB released its Monthly Complaint Snapshot for June 2016, where the “Product Spotlight” was on consumer loans with a new “Subproduct Spotlight” feature on auto lending. To date, the CFPB has handled over 900,000 complaints. However, this number includes a large amount of submissions directed to other agencies. Consumer loan complaints represented four percent of...June 23, 2016As the overall default reading recorded its lowest point dating back a decade, the auto loan segment of the S&P/Experian Consumer Credit Default Indices made another move away from the 1-percent level in May, dipping 5 basis points below the previous month’s reading. According to data through May and released on Tuesday by S&P Dow Jones Indices and Experian, analysts indicated the auto...June 16, 2016On Thursday, June 16, 2016, the CFPB posted on its blog an advisory titled: “Arm yourself with knowledge when shopping for an auto loan.” In addition to the agency’s new auto education tool, the Office of Servicemembers noted servicemembers should especially be familiar with: Reductions of interest rate under the Servicemembers Civil Relief Act; Permission from lenders to take vehicles overseas;...