On July 10, the Consumer Financial Protection Bureau (CFPB) announced it was moving forward with the arbitration rule proposed last year. Under the rule, companies may not use arbitration clauses to stop consumers from taking part in class actions. The rule will be effective 60 days from the date it is published in the Federal Register. Should a company wish to include … [Read more...] about Does July’s CFPB Rule Signal the End of Consumer Arbitration?
Dealers often tell our consultants that their dealership has written policies and is compliant, or that its DMS provides federal notices and reminders, so compliance-wise it’s covered. Many businesses truly believe that having a written policy and a DMS that spits out privacy, credit score disclosure, and adverse action notices is all that is required for front-end … [Read more...] about Dealership Compliance Shouldn’t Be a Case of “File It and Forget It”
As of June 20, the first 150 days of the Trump administration had come and gone. Regardless of which side of the aisle you hail from, it is safe to say the days have been interesting, different, confusing at times, and either productive or a failure depending on your point of view. The question that concerns us, however, is: What has changed in the industry? Business as … [Read more...] about 150 Days of New Presidential Administration: No Changes to Dealership Compliance Requirements
Your dealership may have what many employers deem to be a reasonable policy for all employees: a zero-tolerance drug policy. You likely test all new personnel before they’re hired, as well as employees who are involved in incidents resulting in injury. You may also conduct random testing. This policy is good business, makes sense, and has been implemented by most … [Read more...] about Why It’s Time to Re-Test Your Dealership’s Drug Testing Policy
Last month, we discussed processes for delivering adverse action notices required by both the Fair Credit Reporting Act (FCRA) and the Equal Credit Opportunity Act (ECOA). This month, I want to touch on a few points for emphasis and clarity. A finance company that has denied credit to a customer will generally send the required adverse action notice. Exceptions exist, … [Read more...] about Watch Out for Adverse Action Gaps