CFPB Provides New Guidance Regarding Repossessions

The CFPB recently released Compliance Bulletin 2022-04 to discuss “risky” repossession practices, as well as practices occurring before and after repossession, that it believes might qualify as prohibited unfair, deceptive, or abusive acts or practices. This presentation discusses the nature of the CFPB’s guidance, how auto finance industry participants should respond, and anticipated future developments in this area. This presentation also tackles the bigger-picture issue: did the CFPB exceed its authority by issuing broad guidance of this nature, including the designation of certain fees as “illegal” for the first time, as part of a compliance bulletin?