Auto Finance

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.
  • July 13, 2017
    CARY, N.C. - Clearly the industry is “disappointed” that the Consumer Financial Protection Bureau earlier this week issued a final rule prohibiting the use of class action waivers in arbitration clauses. The American Financial Services Association, the National Independent Automobile Dealers Association and the American Bankers Association all used that specific adjective when relaying their...
  • July 13, 2017
    The Consumer Financial Protection Bureau's arbitration rule , issued Monday, could put dealerships and auto lenders at risk for class-action lawsuits. But some experts questioned whether the rule will ever take effect, while various industry associations quickly issued statements denouncing the rule. The rule prohibits banks and other financial services companies from including mandatory...
  • June 21, 2017
    June 21, 2017 The Honorable James Mattis Secretary of Defense 1000 Defense Pentagon Washington, DC 20301-1000 Dear Mr. Secretary, As we approach the first anniversary of the implementation of the Department of Defense’s amended Military Lending Act (MLA) Regulation, the Financial Trade Associations – the American Bankers Association, the American Financial Services Association, the Association of...
  • June 21, 2017
    On 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, 2017
    On 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, 2017
    Download 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, 2017
    Even 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, 2016
    Breaking: 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...

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