Credit Acceptance and National Trade Associations Challenge the CFPB and NY AG’s Attempt to Disregard TILA and Regulate the Indirect Auto Finance Industry Through Litigation
Troutman Sanders
APRIL 5, 2023
The Second Circuit has rejected similar pleading tactics in the past, and the CFPB’s official interpretation of the governing disclosure regulations is clear that assignment discounts are not finance charges unless separately imposed on consumers in individual transactions — a test the complaint’s “cash price proxy” theory does not satisfy. (3)
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