In Part 1 of this column we highlighted some of the emerging patterns in how the Consumer Financial Protection Bureau (CFPB) has ruled that companies have been “abusive” in their treatment of consumers under the authority found in Title X of the Dodd-Frank Wall Street and Consumer Protection Act of 2010. Here we will discuss another example that arose just last month.
The standard is pliable in terms of industry application. In the PayPal case, which we discussed previously, the CFPB deployed the abusive authority on financing for eBay purchases and facts relating to online enrollment and account servicing. More recently, the CFPB now applies the authority to military lending in the context of servicing retail installment loans originated by auto dealers. An analysis of the claims in the CFPB’s case last month against Security National Automotive Acceptance Company (SNAAC) provides clarity on the kinds of acts and practices that trigger abusiveness claims.
Background
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