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Prospective Creep of CFPB into Auto Finance

The Consumer Financial Protection Bureau’s (“CFPB”) newly-appointed Director, Richard Cordray, is no friend of auto dealers. When he was Attorney General of Ohio, Mr. Cordray brought numerous actions against dealers for alleged violations…

New “Safe Harbor” Privacy Notice Takes Effect January 1, 2011

The FTC and Federal Reserve Board have published a new form of privacy notice that, if properly completed and followed, will give dealers a “safe harbor” (protection) from liability. It is a simple form…

The Year of Enforcement Continues

The CFPB’s First Enforcement Action and Its Implication for Auto Dealers The Consumer Financial Protection Bureau (“CFPB”) entered into its first enforcement action consent decree with Capital One Bank ordering Capital One to pay…

NEW: Manage Auto Financing in Real Time with DealerTrack Mobile!

Take your deal workflow to the next level by adding new intuitive mobile apps from DealerTrack. Securely track the pulse of your deals within finance and vehicle inventory workflows whether you are on the…

Compliance Definition of the Week

UDAPs – (Unfair and Deceptive Acts and Practices laws) – Includes FTC Act Section 5 and similar state laws used frequently by the FTC and state Attorneys General to correct and obtain damages for consumer…

CFPB Begins Taking Tips from Whistleblowers

The Consumer Financial Protection Bureau is soliciting information from whistleblowers and other knowledgeable sources about potential violators of federal consumer financial laws. The CFPB is welcoming information from current or former employees, contractors, vendors,…

The Threat Within: Internal Data Breaches and ID Theft

Automotive News recently reported that an Arizona dealer’s F&I Manager was involved in a fraud ring stealing the identities of dealership customers and sharing them with a criminal enterprise. At least a dozen identity…

Compliance Definition – Consumer Financial Protection Bureau (“CFPB”)

An independent federal agency established by the Dodd-Frank Act to enforce consumer protection regulations and issue new regulations prohibiting unfair, deceptive, or abusive acts and practices, among other things. Auto dealers that sell, lease…

New 2011 Compliance Initiatives May Signal Auto Dealer Scrutiny

The summer of 2011 has brought a dramatic increase in compliance enforcement proceedings against banks and financial institutions. Many of the issues apply to auto dealers as well and dealers will be likely candidates…

Auto Compliance after July 21, 2011: New Rules. New Players. New Risks

July 21, 2011 marked an important date for auto dealers and consumer creditors generally. It was the one-year anniversary of the signing of the Dodd-Frank Act as well as the “designated transfer date” for…

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