NY Revives Fair Lending Risks For Indirect Auto Lenders
Law360 (September 14, 2018, 1:25 PM EDT) -- The recent rollback of Obama-era fair lending enforcement does not mean that fair lending risk has disappeared. Many states are stepping up to fill in where the Trump administration's Consumer Financial Protection Bureau, also known as the Bureau of Consumer Financial Protection, or BCFP, has backed off. For example, on Aug. 23, 2018, the New York Department of Financial Services issued a guidance document expressing the department's position on the application of New York state's fair lending law to indirect auto lending. The key takeaways are:
The guidance looks a lot like the now-rescinded March 2013 indirect auto lending bulletin;...
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