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Auto Dealer Regulation Post-Dodd/Frank

Auto Dealer Regulation Post-Dodd/Frank. Americans for Financial Reform Field Webinar. Dealer Regulation. FTC retains regulatory authority over dealers Streamlined regulatory authority Enforcement power FTC can regulate markups and yo-yo’s as dealer conduct

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Auto Dealer Regulation Post-Dodd/Frank

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  1. Auto Dealer Regulation Post-Dodd/Frank Americans for Financial Reform Field Webinar

  2. Dealer Regulation • FTC retains regulatory authority over dealers • Streamlined regulatory authority • Enforcement power • FTC can regulate markups and yo-yo’s as dealer conduct • FTC has already taken enforcement action against: • Pay off your trade in no matter what scams • Car loan modification scams • FTC Roundtables

  3. Dealer Regulation • CFPB has rulemaking authority under consumer financial laws and to prevent unfair, deceptive or abusive acts. • Dodd-Frank included exemption for franchise car dealers and larger independent dealers. • Exclusion: Car dealers that primarily engage in the sale or lease of vehicles to consumers AND service of vehicles AND routinely assign finance contracts to unaffiliated third parties are exempt. • Takes most franchise dealers out (those with service departments), leaves independents without service department and Buy Here-Pay Here lots in.

  4. Dealer Regulation • Takes most franchise dealers out (those with service departments), leaves independents without service department and Buy Here-Pay Here lots in. • CFPB also has authority over the lenders that buy installment contracts from dealers. • Dealer markup • Conditional financing – TILA implications • ECOA/Fair Lending • Military Impact

  5. Contact Information Chris Kukla Senior Vice President Center for Responsible Lending chris.kukla@responsiblelending.org www.responsiblelending.org

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