AFSA’s State Government Affairs team sent a comment letter to the Massachusetts Office of Attorney General (OAG) on the proposed regulations related to Unfair and Deceptive Fees. In the letter, AFSA highlights concerns with the proposed regulations due to their wide-ranging scope and ambiguous wording, leaving the potential impact on financial services uncertain.
The letter lays out recommendations to extend the comment period in 2024, allowing more participants to provide adequate comments. AFSA requests the OAG clarify that commercial transactions are exempt by restricting the definition of “sale” to” “sales specifically intended for personal, family, or household use by a consumer.” Furthermore, it remains uncertain whether the definition of “sale” encompasses or excludes loan or leasing transactions, regardless of whether they are consumer or commercial in nature.
AFSA also cites concerns of disclosures being inconsistent with federal law, suggesting regulation amendments to exclude financial services products from their mandates. Additionally, the letter raises concerns of whether conditional fees would be included within the definition of “total price,” requiring disclosure in accordance with the regulations.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
Massachusetts Proposed Junk Fee Regulations
Jan 11, 2024
AFSA’s State Government Affairs team sent a comment letter to the Massachusetts Office of Attorney General (OAG) on the proposed regulations related to Unfair and Deceptive Fees. In the letter, AFSA highlights concerns with the proposed… Read the rest
The Economic Outlook for 2024: Recession? Probably Not. Vibecession? Definitely.
Jan 11, 2024
AFSA Chief Economist Tim Gill has joined the prestigious The Wall Street Journal’s longstanding Economic Forecasting Survey panel. The panel consists of approximately 75 economists from academia, financial institutions, consulting… Read the rest
Small Business Review Panel Issues Report On FCRA Rulemaking
Jan 11, 2024
This week the Small Business Review Panel issued its “Final Report” on the CFPB’s Fair Credit Reporting Act (FCRA) proposals. This is part of the Consumer Financial Protection Bureau’s rulemaking process. The Small Business Regulatory … Read the rest
New Year, Old Issues
Jan 11, 2024
Welcome back! This week, both the House of Representatives and the Senate are in session following their holiday break. Below are some highlights from the first week back:
The State of the Union Marches On … House Speaker Mike Johnson (R-LA)… Read the rest
January White Paper: 2024 State Legislative Session Preview
Jan 04, 2024
On January 2, AFSA’s State Government Affairs (SGA) team released its latest white paper. This month’s white paper provides a 2024 State Legislative Session preview and 2023 year-in review.
In 2023, California and D.C. addressed … Read the rest
AFSA Suggests Changes to Financial Data Rulemaking
Jan 04, 2024
Last week, in a letter to the Consumer Financial Protection Bureau, AFSA reiterated support for innovation in the financial services industry but cautioned against overly restrictive use limitations. The CFPB’s proposed rulemaking to… Read the rest
CEO Roundtable | 2024 Vehicle Finance Conference & Expo
Jan 03, 2024
Get the insights you need for 2024 and beyond from the industry leaders in the know at the capstone session of AFSA’s Vehicle Finance Conference & Expo: the CEO Roundtable. Be a part of 2024’s best vehicle-finance industry gathering, with… Read the rest
Lies & Loans: What’s on the Vehicle Finance Fraud Horizon?
Dec 21, 2023
From false documents, overstating income and phantom loans to synthetic identities and leveraging stolen data on the Dark Web, vehicle finance fraudsters are adapting and innovating as quickly as the technology and techniques used to trap… Read the rest
AFSA & Trades: CFPB AO Not A-Okay
Dec 20, 2023
Earlier this week AFSA joined the Bank Policy Institute, the Consumer Bankers Association and the U.S. Chamber of Commerce in a letter to the Consumer Financial Protection Bureau (CFPB) raising concerns and requesting clarification on … Read the rest
AFSA Makes Publication Request
Dec 18, 2023
In November the California Third Court of Appeals issued an unpublished decision that affects the vehicle finance industry, Stettner v. Mercedes-Benz Financial Services USA, LLC. Unpublished opinions are prohibited from being cited … Read the rest