The FTC’s proposal would impose a number of new substantive and disclosure requirements on auto dealers in connection with the car buying or leasing process. We first discuss NADA’s comment letter to the FTC on the proposal, including NADA’s concerns with the process used by the FTC to issue the proposal and with the proposal’s disclosure, recordkeeping, website posting, and other requirements. We then discuss the auto finance industry’s concerns with the proposal, including the risks arising from the FTC Holder Rule, the industry’s call for safe harbors, and other steps auto finance companies can take to mitigate risks in connection with ancillary products. We conclude with a discussion of the CFPB’s focus on ancillary products, including CFPB supervisory activity, potential areas of CFPB scrutiny, and the CFPB’s use of its authority to supervise auto finance companies to influence dealer behavior.
John Culhane, a partner in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.
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By Ballard Spahr LLP
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The FTC’s proposal would impose a number of new substantive and disclosure requirements on auto dealers in connection with the car buying or leasing process. We first discuss NADA’s comment letter to the FTC on the proposal, including NADA’s concerns with the process used by the FTC to issue the proposal and with the proposal’s disclosure, recordkeeping, website posting, and other requirements. We then discuss the auto finance industry’s concerns with the proposal, including the risks arising from the FTC Holder Rule, the industry’s call for safe harbors, and other steps auto finance companies can take to mitigate risks in connection with ancillary products. We conclude with a discussion of the CFPB’s focus on ancillary products, including CFPB supervisory activity, potential areas of CFPB scrutiny, and the CFPB’s use of its authority to supervise auto finance companies to influence dealer behavior.
John Culhane, a partner in Ballard Spahr’s Consumer Financial Services Group, hosts the conversation.
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