Yesterday, the Consumer Financial Protection Bureau (CFPB) issued an advisory on what it calls “junk fees.” AFSA has long been engaged on this issue and has argued that the pejorative term “junk fees,” while sure to get headlines, fundamentally misunderstands how the consumer credit market operates and in many cases mis-portrays to consumers and the media what those fees address.
In February, AFSA wrote on CFPB and Federal Trade Commission (FTC) proposals the agencies claimed would control so-called “junk fees.” The FTC must follow certain specific guidelines for trade rules that declare an act or practice unfair or deceptive. In the FTC’s Advanced Notice of Proposed Rulemaking (ANPR), the line of questioning shows that it is engaging in a fishing expedition, rather than clear and appropriate rulemaking. In that same time frame, the CFPB proposed a rule specifically targeting credit card late fees that dismissed the crucial role of deterrence such late fees play in serving the best interest of consumers.
In July, AFSA filed comments for the subcommittee hearing entitled, Taking Account for Fees and Tactics Impacting Americans’ Wallets regarding fees on installment loans.
As we’ve noted, financial institutions want to serve their customers and provide them with credit products and services that provide benefits. As even the CFPB notes, many financial institutions have adjusted eliminated fees for non-sufficient funds, saving consumers an estimated $2 billion every year.
In short, the industry wants to be both a good corporate citizen and serve their customers. But clear rules of the road set through the well-established rulemaking process – not simply promulgated via press release – would best serve all parts of the marketplace.
Rules Not Releases
Oct 12, 2023
Yesterday, the Consumer Financial Protection Bureau (CFPB) issued an advisory on what it calls “junk fees.” AFSA has long been engaged on this issue and has argued that the pejorative term “junk fees,” while sure to get headlines, fundamentally… Read the rest
Ep. 55 | Alternative Data Download w/ Equifax
Oct 12, 2023
In this edition of the AFSA Extra Credit Podcast, we chat with Lena Bourgeois, SVP & General Manager of Automotive & Insurance with Equifax about alternative data. It’s a term that gets thrown around a lot but Lena gives us the download… Read the rest
Business Partner Webinar | Auto Finance Innovation: When To Build, When To Buy?
Oct 09, 2023
Auto Finance Innovation: When To Build, When To Buy?
October 12, 2023 | 2:00 p.m. ET
Continuous digitization is a must in today’s world. But with limited resources, time and budgets, it can be tough to know what path to take. Should you build an… Read the rest
FEATURED BUSINESS PARTNER | GOLDPoint Systems
Oct 01, 2023
The featured Business Partner for the month of October is GOLDPoint Systems
GOLDPoint Systems offers one of the most complete Loan Management Software Systems in the Direct and Indirect market, covering the complete loan life cycle. Our … Read the rest
Do-Nothing Policies Can Do Harm
Sep 27, 2023
The Urban Institute has been doing yeorman’s work providing independent, fact-based analysis on the effects of consumer credit rate caps. Taken together with other independent, academic analysis of rate caps, there is a growing body of… Read the rest
Registration Open for 2024 Vehicle Finance Conference
Sep 27, 2023
It’s time! Register for the 2024 Vehicle Finance Conference & Expo today and enjoy Early Bird Pricing!
What can you expect?
Influential Speakers. Gain insights and inspiration from incredible speakers, including our keynote:… Read the rest
Industry Expertise | Audit-Ready Best Practices for Lenders
Sep 27, 2023
AFSA’s Industry Expertise allows Business Partners to provide thought leadership and best practices information directly with AFSA member companies. For more information about taking part, contact Dan Bucherer.
Audit-Ready Best Practices… Read the rest
AFSA Applauds Bureau CRO Consumer Advisory
Sep 25, 2023
Today, the Consumer Financial Protection Bureau (CFPB) issued an advisory reminding consumers that they have the right to see results from Credit Repair Organizations (CRO) before they pay and, more importantly, that they do not need to … Read the rest
2023 Annual Meeting Breakouts
Sep 21, 2023
The AFSA Annual Meeting is full of great general sessions and breakouts, too. Don’t miss out on two concurrent sets of breakouts Wednesday morning!
Wednesday, October 4th at 10:00 a.m. – 10:45 a.m.
Fraud in the Age of AI
The rapid… Read the rest
Accountability is Paramount
Sep 21, 2023
This week, the House Subcommittee on Financial Institutions and Monetary Policy held a hearing entitled A Holistic Review of Regulators: Regulatory Overreach and Economic Consequences, which sought to explore the interaction and economic… Read the rest