As the Chair of my firm’s Auto Finance Team, a multidisciplinary team of attorneys serving the auto finance industry, I’ve heard my share of complaints about the CFPB’s newfound focus on auto finance companies, banks, and non-bank entities that serve the auto finance sector.
In the course of my discussions with clients, colleagues, industry representatives, my study of the agency’s March 2013 guidance and rules, and review of articles relative to the CFPB’s initiative, I’ve reached the conclusion that the agency’s regulation of and involvement with the auto finance industry as to its business with dealers is simply wrong — legally and ethically — and, most importantly, because it is directly counterproductive to its goal of protecting American consumers.
