Tag: non-bank

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CFPB Proposes New Rule to Oversee Nonbank Auto Finance Companies
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CFPB and FTC Memorandum of Understanding Aims to Coordinate Non-Bank Enforcement and Allow Information-Sharing

CFPB Proposes New Rule to Oversee Nonbank Auto Finance Companies

By: Melanie Brody, Anjali Garg*
*Ms. Garg is not admitted in D.C. She is supervised by Stephanie Robinson, a member of the D.C. Bar.

The CFPB proposed a new rule on September 17, 2014, that would enable the Bureau to oversee nonbank auto finance companies. With the proposal, the CFPB takes another step toward expanding its supervisory authority over nonbanks. The Bureau released the proposed rule along with a report on recent examinations of bank auto lending activities and a white paper describing its proxying methodology for imputing race and ethnicity when analyzing fair lending compliance on non-mortgage credit products.

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CFPB and FTC Memorandum of Understanding Aims to Coordinate Non-Bank Enforcement and Allow Information-Sharing

By: David I. Monteiro

Over the weekend, the CFPB and the FTC executed a Memorandum of Understanding (“MOU”) between the two agencies that clarifies how they will share information and coordinate efforts with respect to companies and issues that fall under both agencies’ jurisdiction. The document contains few surprises but offers some insight into the steps the agencies are taking to prevent unnecessary duplication and inconsistency. Read More

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