Archive | Compliance

The Return of the Leg

The Return of the Leg

I once made a list of all the ways certain dealers — a very small percentage — fleeced consumers through the F&I process, and the list was a long one. Some of those practices should have disappeared years ago, or so I had thought, based upon litigation and regulator prosecution. But, as in popular styles … Read More »

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Your Brother’s Keeper – You May Now be Responsible for Your Vendor’s Actions

Your Brother’s Keeper – You May Now be Responsible for Your Vendor’s Actions

Adam and Eve begat Cain and Abel. Abel slew Cain. When questioned by the Lord as to the whereabouts of Cain, Abel defiantly asked this question in reply, “Am I my brother’s keeper?” To which the CFPB responded, “Yes, you are.” To quote the CFPB, “A well planned, implemented, and maintained compliance program will prevent … Read More »

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CFPB Auto Finance Guidance Losing Momentum: What’s Next?

CFPB Auto Finance Guidance Losing Momentum: What’s Next?

The much-heralded CFPB Auto Finance Guidance issued in March 2013 appears to be losing its momentum in the first part of 2015. You will recall that the Consumer Financial Protection Bureau (CFPB), which lacks jurisdiction under the Dodd-Frank Act over most franchised automotive dealers, claimed that lenders allowing dealers to mark up lender buy rates … Read More »

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The Past is Prologue- Regulatory Retribution Against Dealers

The Past is Prologue- Regulatory Retribution Against Dealers

To paraphrase the Bible, there is nothing new under the sun. This is also true of consumer law as it relates to the car business. In spite of a new consumer protection agency, the Consumer Finance Protection Bureau or CFPB, and a newly empowered FTC, these agencies pursue the traditional cases against dealers, as they … Read More »

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Not Your Father’s Payment Assurance Device – A Plea to Regulators

Not Your Father’s Payment Assurance Device – A Plea to Regulators

Back in the heyday of WordStar, Lotus 123, and other advanced PC programs in the early 1990’s, I had the rare privilege of being a receiver for a Buy Here Pay Here store. I was responsible for winding down its operations as a result of a RICO forfeiture case on behalf of the Florida Attorney … Read More »

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The Black Box of Government Regulation

The Black Box of Government Regulation

The term “black box” refers to the concept of a device, or a box, in which there is input, something is moved or transferred into it, and voila, out of this device or box there is a measurable and quantifiable outcome. But, the workings of the box itself remain a total mystery. The human brain, … Read More »

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