Welcome to Hudson Cook Insights (formerly Basis Points) - a collection of articles written each month by the attorneys of Hudson Cook, LLP, in an effort to keep their clients and other compliance professionals informed about current trends and developments in consumer credit finance that will affect the way they do business.
As most creditors now know, the recent expansion of the Military Lending Act ("MLA") became effective in October of 2016. The Final Rule was originally published on July 22, 2015. In addition, the Department of Defense ("DOD") published interpretive guidance on August 29, 2016-little more than a month before the effective date. However, "credit extended in a credit card account under an open-end (not home-secured) consumer credit plan" maintains a temporary exemption from coverage until October 3, 2017. Moreover, the DOD retained authority to potentially extend that exemption for another year, meaning that credit cards may not even be included within the definition of "consumer credit" under the MLA until as late as October 3, 2018. Despite the delayed coverage date, we suggest that credit card providers start preparing now.[more»]
After enough fits and starts to make a 1971 Ford Pinto with a bad timing belt look like a high performance vehicle by comparison, on November 18, 2016 the Federal Trade Commission published its Final Rule amending the Used Motor Vehicle Trade Regulation Rule ("Used Car Rule").[more»]
Every time you begin to think you've heard every strange story that has ever been told about car dealers, along comes another one. This one comes from my home state, Georgia, as recently reported by The Telegraph, which relied on the allegations in the car buyer's lawsuit because the reporter was unsuccessful in trying to reach the dealership's attorney and general manager.[more»]
This month's report features activity from the Consumer Financial Protection Bureau, the Federal Reserve Board, the Federal Communications Commission, and the Federal Trade Commission. Only a few items we mention this month are expressly auto-related, but the rest might be of interest to those in the auto sales, finance, or leasing business.[more»]
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