Automotive Finance: Impact of the Dodd-Frank Act

摘要

Under the Dodd-Frank Act, the CFPB has been established and provided authority to regulate components of automotive finance transactions. Compared to the regulation of mortgages and credit cards, the impact on automotive finance has been limited thus far and will not entail major changes to automotive finance creditors' forms and procedures. Once the CFPB Director prioritizes his enforcement agenda and additional regulations have been promulgated, it will be easier to assess the full impact of the Dodd-Frank Act on automotive finance. Furthermore, states will likely play a greater regulatory and enforcement role in connection with automotive finance. State Attorneys General will likely flex their new enforcement powers and subsidiaries of national banks may be subject to greater scrutiny by state banking and licensing regulators.