ARTICLE
26 September 2019

CFPB Highlights Supervisory Exam Findings On Consumer Loans

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The Consumer Financial Protection Bureau ("CFPB") highlighted findings from supervisory examinations completed between December 2018 and March 2019.
United States Finance and Banking

The Consumer Financial Protection Bureau ("CFPB") highlighted findings from supervisory examinations completed between December 2018 and March 2019. The examinations covered (i) automobile loan origination, (ii) credit card account management, (iii) debt collection, (iv) furnishing of information by credit reporting companies, and (v) mortgage origination.

In its periodic publication, Supervisory Highlights, the CFPB reported examples of:

  • auto lenders engaging in abusive practices when selling add-on guaranteed asset protection (GAP) products (i.e., financial products that cover the difference between the amount owed on an auto loan and the amount received from an auto insurer);
  • credit card issuers failing to provide necessary disclosures when advertisements contained certain pricing terms, i.e., "triggering terms";
  • credit card issuers using a consumer deposit to offset credit card debt;
  • credit card issuers misleading consumer credit cardholders by implying that the issuer could repossess or foreclose in credit card collections;
  • credit card issuers using deceptive marketing techniques to secure credit card accounts;
  • debt collectors falsely representing the amount and legal status of consumers' debt; and
  • firms failing to meet accuracy and dispute handling requirements under the Fair Credit Reporting Act.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More