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AFSA Comments on New York City Proposed Rules for Secondhand Auto Dealers

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On February 28, AFSA submitted a comment letter to the New York City Department of Consumer Affairs regarding the Department’s proposed rulesfor secondhand auto dealers. The proposed rules would implement Local Laws 197 and 198 of 2017, which passed the City Council in September. The laws and proposed rules set certain requirements for secondhand auto dealers in the city, including disclosure of car buyer’s bill of rights. In addition to disclosure of the contract APR, there is a requirement to disclose the lowest APR offered to a buyer by any finance company for a loan with same term and down payment and the APR offered to a buyer by the selected finance company. AFSA’s letter urged the Department to reconsider its proposed disclosure form and pointed out that the disclosure of up to three different APRs may confuse consumers. The letter also noted that the Federal Reserve Board previously considered and specifically decided against requiring a similar disclosure of fees for dealer participation due to the minimal consumer benefit.

The Department formally presented the rules and accepted feedback at a February 28 hearing. AFSA will continue to monitor the rulemaking process and keep members apprised of any future changes.

AFSA Comments on New York City Proposed Rules for Secondhand Auto Dealers
Feb 28, 2018

On February 28, AFSA submitted a comment letter to the New York City Department of Consumer Affairs regarding the Department’s proposed rulesfor secondhand auto dealers. The proposed rules would implement Local Laws 197 and 198 of… Read the rest

Mulvaney Jabs Warren for Lack of ‘Civil Discourse’ in Payday Loan Debate
Feb 26, 2018

Mick Mulvaney, acting director of the Consumer Financial Protection Bureau (CFPB), sent a letter to Sen. Elizabeth Warren (D-Mass.) defending himself against accusations that the bureau's actions on payday lending curbs under his… Read the rest

Compliance Considerations: Federal Reserve Board Seeks Comments on Reg. M Proposed Rule
Feb 15, 2018

Philip Bohi, VP Compliance Education

On January 3, 2018, the Federal Reserve Board (“Board”) issued for public comment a Proposed Rule affecting Consumer Leasing Regulation M (“Reg. M”). But, you may observe,… Read the rest

Preparing for your state exam: experts offer pragmatic advice
Feb 15, 2018

Some state examiners feel that multi-state exams are a more efficient process today than they were several years ago. The question is: are they better for industry? Some say worse; others say better. But all agree, there are still some drawbacks… Read the rest

AFSA Education Foundation to Survey Members About Financial Education Offerings
Feb 14, 2018

As an industry, we understand the importance of personal financial education and, yet, we know there is opportunity to do so much more. To that end, the AFSA Education Foundation Board is committed to ensuring that it is easy and impactful for… Read the rest

AFSA Launches Enhanced Industry Buyers Guide
Feb 07, 2018

AFSA is pleased to announce its newly enhanced Online Industry Buyer’s Guide that is prominently displayed on AFSA’s Homepage. The Guide provides contact information and identifies the products and services provided by AFSA’s… Read the rest

Registration Open for AFSAEF’s The EDGE and the UNC Leadership program!
Feb 06, 2018

Registration has opened for the American Financial Services Association Education Foundation’s (AFSAEF) THE EDGE program. THE EDGE provides high quality training for branch managers and team leaders by providing layered modules… Read the rest

Ron Insana provides entertaining, non-stop commentary
Feb 05, 2018

AFSA’s first ever Law & Compliance conference closed last week with Ron Insana offering his unique perspectives on the economy, Washington and the global geo-political challenges facing the United States. Insana is a contributor… Read the rest

Top Fraud Risks Facing Financial Institutions in 2018
Jan 26, 2018

A new year brings with it new challenges and some old ones as well. In 2018, financial institutions will continue to face Synthetic Identity Fraud, Loan Fraud and ADA Website Accessibility Compliance risks. Are you prepared?

ADA website accessibility… Read the rest

CFPB Releases RFI on CID Processes
Jan 24, 2018

On Wednesday, the Consumer Financial Protection Bureau (CFPB) released its request for information (RFI) regarding bureau civil investigative demands and associated processes. Comments will be due 60 days after publication in the Federal… Read the rest

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