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Emergency Rule Petitioned

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AFSA’s State Government Affairs team sent a petition for emergency rule or order to the New Hampshire Bank Commissioner regarding NH HB 1243AFSA has been continuously engaged with the New Hampshire Banking Department throughout the finalization process of HB 1243, a substantial re-write of the state’s longstanding vehicle finance code.

 

The petition urged the commissioner to postpone the enforcement of new provisions outlined in HB 1243, signed into law by Governor Sununu on August 2nd. AFSA argues that the immediate implementation of these provisions is impractical. The letter emphasizes that the required changes, including updates to forms and operational procedures, cannot be immediately complied with. This creates a challenging situation where dealers and financiers must either continue under the old rules or halt vehicle sales, both of which could disrupt consumer access to vehicle financing.

 

AFSA requests an emergency rule to delay enforcement until January 1, 2025, to prevent unnecessary interruptions in vehicle financing. AFSA stresses that the new law’s retroactive effective date exacerbates the problem, particularly for members who rely on securitization for funding. Without this critical source of funding, the ability of these members to support vehicle purchases in the state could be severely impacted, ultimately harming both dealers and consumers.

 

This petition and SGA’s other recent letters can be found in the direct advocacy section of AFSA’s website.

Emergency Rule Petitioned
Aug 29, 2024

AFSA’s State Government Affairs team sent a petition for emergency rule or order to the New Hampshire Bank Commissioner regarding NH HB 1243AFSA has been continuously engaged with the New Hampshire Banking Department throughout the finalizationRead the rest

More CFPB Concerns
Aug 29, 2024

Last week AFSA sent a letter to the CFPB reiterating enforcement concerns with the nonbank registry. As AFSA previously noted, the rule is overly broad and conflicts with a multitude of consumer protections already in place at both the federalRead the rest

Women’s Equality Day!
Aug 26, 2024

Today, August 26th, AFSA marks the 104th anniversary of Women’s Equality Day and the significant achievement of the 19th Amendment’s ratification. This amendment, passed in 1919 and ratified in August 1920, made an historic… Read the rest

Agency Actions Must Be Limited
Aug 23, 2024

This week, AFSA and other trade organizations filed an amicus brief in support of a vehicle finance company facing an enforcement action from the CFPB, which is attempting to amend settled law that the financial services industry has operated… Read the rest

Back to School Spending and Credit Access
Aug 21, 2024

Back-to-school season is well underway, bringing with it the need for supplies, new clothes, books, and more. According to a National Retail Federation survey, back-to-school outlays for the coming academic year will amount to $39 billion,… Read the rest

Concerns on CFPB’s Medical Debt Rule
Aug 13, 2024

Yesterday, AFSA submitted comments to the CFPB on its proposed rule concerning medical debt.  In the letter, AFSA highlighted four specific issues with the proposed rule:

  • The CFPB lacks authority for this rulemaking
    • At the outset, the CFPB
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Industry Expertise | Lien on Me: CHAMP Titles ELT Will Be Your Friend
Aug 12, 2024

Industry Expertise” is sponsored content produced by AFSA’s Business Partners’ to provide thought leadership and best practices for AFSA member companies. . For more information about this sponsored content opportunity, contact DanRead the rest

Loan Forgiveness Denied
Aug 08, 2024

This week, AFSA joined DACO Investments, Westside Credit Corporation, Inc., Motorists Acceptance Corporation, and Challenge Financial Services in filing an Appellant’s Opening Brief in the 5th Circuit.  AFSA’s members, like so many … Read the rest

Wither the Soft-Landing?
Aug 05, 2024

Recent stronger-than-expected U.S. economic growth was a top headline in the financial media, and a rare economic soft landing seemed like a sure thing. The major stock market indexes were within shouting distance of all-time highs, and … Read the rest

Featured Business Partner | RSM
Aug 01, 2024

The featured Business Partner for the month of August is RSM.

RSM US LLP is the leading provider of audit, tax and consulting services focused on the middle market, with 12,000 professionals in 84 cities nationwide. Our full range of services

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