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Auto Finance – CFPB

The CFPB Auto Finance Procedures cover both loan origination and servicing processes and are applied to automobile lenders, lessors, and servicers.

The following modules are the active areas of controls, which will be assessed and reported on during a CFPB assessment:

Module 1 – Company Business Model

  • Overview of the types of products and services offered
  • Organizational overview and key responsibilities of key managers

Module 2 – Compliance Management System

  • Overall Compliance Management System
    • Chief Compliance Officer
    • Internal Audit
    • Reporting to the Board
  • Affiliates and 3rd party relationships
  • Internal structure, controls, and compliance management
    • Independence and reporting structure
    • Applicable law
    • Appropriateness
    • Timeliness
    • Corrective and preventative action

Module 3 – Advertising and Marketing

  • Affiliates and 3rd party relationships
  • Truth in Lending Act/Regulation Z
  • Fair Credit Reporting Act/Regulation V
  • Consumer Leasing Act/Regulation M
  • Prescreening Process & Consumer Opt-Out Notices

Module 4 – Application and Origination

  • Application and Origination
  • Truth in Lending Act/Regulation Z disclosures
  • Electronic Fund Transfer Act/Regulation E
  • Equal Credit Opportunity Act/Regulation B
  • Fair Credit Reporting Act/Regulation V disclosures
  • Consumer Leasing Act/Regulation M disclosures
  • Gramm-Leach-Bliley Act/Regulation P

Module 5 – Payment Processing, Account Maintenance and Optional Products

  • Payment Processing
  • Assessment of Fees
  • Application of Payment
  • Periodic Statements
  • Electronic Fund Transfer Act/Regulation E
  • EFTA and Regulation E
  • UDAAP
  • Leases

Module 6 – Collections, Debt Restructuring, Repossessions, and Accounts in Bankruptcy

  • Fair Debt Collection Practices Act (FDCPA)
  • UDAAP
  • Debt Restructuring/Workouts
  • Bankruptcy

Module 7 – Customer Complaints and Inquiries

  • UDAAP/other risks to consumers

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