Almost six months after nominating Richard Cordray to head the Consumer Financial Protection Bureau, Pres. Barack Obama bypassed a Senate vote and used a “recess” appointment to install the former Ohio Attorney General as head of the CFPB.

With a director in place, the CFPB can start to regulate what it deems “unfair, deceptive, or abusive acts or practices,” commonly referred to as UDAAP.

For sectors like auto finance and debt collection, the agency must first define “larger participants” before supervision can be initiated. “We have been hard at work preparing an initial ‘larger participant’ rule,” according to a CFPB statement. “We will issue a proposed initial rule very soon.”

Many companies might be prepared as the CFPB gains momentum, while others might need to kick up their compliance and form strategies to save them from reprimands.  One mandate that could affect auto financiers relates to arbitration, a process commonly called for in retail installment contracts. Section 1028 of the Dodd-Frank Wall Street Reform and Consumer Protection Act — the legislation that created the CFPB — requires the agency to conduct a study of pre-dispute arbitration provisions in consumer financial services contracts, report to Congress, and, if warranted, prohibit or regulate such provisions.

Once the ball gets rolling, what else will it mean for the auto finance industry? What do you think should be added to Cordray's To-Do List? 

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