The Consumer Financial Protection Bureau Weighs in on Collateral Protection Insurance
The Bureau does not regulate insurance directly – that’s the province of individual states – but its authority to implement and enforce consumer financial laws grants the CFPB broad powers where insurance and consumer finance intersect. CPI is an example of one such intersection.
With Inventory Costs Up, Should Lenders Re-Evaluate Their CPI Rates?
The pandemic-driven increase in the cost of used auto inventory has driven the severity of auto physical damage claims up. As people are returning to work, the frequency of auto physical damage claims are on the rise. What does this mean for lenders with CPI programs?
Proposed “All-In APR” Throws the Baby Out With the Bathwater
At its core, the Protecting Consumers from Unreasonable Credit Rates Act is a denial of the right to contract. It is a nanny state prescription that disregards consumer choice in favor of formulaic restrictions dreamed up by well-meaning people who most likely will never feel its effects.
Think UDAAP Doesn’t Apply to Your CPI Program? Think Again
Although the CFPB does not regulate the business of insurance, the agency may still pursue UDAAP claims arising from the use of insurance products. In other words, the CFPB may investigate an insurer, an insured creditor or both based on claims that an insurance product is being used in a way that is unfair, deceptive or abusive. So it’s not enough merely to choose an admitted insurance product. You have to use it in a way that avoids harm to consumers.