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.

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 watch have to do with campaign donations received from the industry. “I reject your insinuation — repeated three times in as many pages — that my actions as acting Director are based on considerations other than a careful examination of the law and facts particular to any matter,” Mulvaney wrote, referring to an earlier letter from Warren to the agency's interim chief.

Philip Bohi, VP Compliance Education

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 such as the lack of uniformity or examiners not requesting the same material from state to state.

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 AFSA members to use its comprehensive, online personal finance course, MoneySKILL®, to support your organization’s financial education, corporate responsibility, and community investment goals.

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 195 Business Partners, including 64 Premier Partners.

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 of learning.

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 to CNBC and MSNBC.

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?

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 Register.