ARTICLE · 29 MARCH 2022

CFPB Issues Bulletin About Auto Repossession, Congressional Republicans Respond

Alston & Bird

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The Consumer Financial Protection Bureau recently released a Bulletin addressing the repossession of vehicles and alerting market participants to what it views as those market participants' legal obligations under federal law governing UDAAP.

United StatesConsumer Protection

John C. Redding

Patrick Eagan-Van Meter

A&B Abstract: The Consumer Financial Protection Bureau ("CFPB" or the "Bureau") recently released a Bulletin addressing the repossession of vehicles and alerting market participants to what it views as those market participants' legal obligations under federal law governing unfair, deceptive, or abusive acts or practices ("UDAAP"). That same day, the CFPB also published an inflammatory Press Release, claiming creditors were engaged in activities causing consumers to "wake up to see their car stolen." Shortly thereafter, a number of Republican Congressmembers responded to the Bulletin and Press Release with a Letter expressing concern that the Bureau's post mischaracterized the activities of vehicle finance companies. The Letter requested information and data supporting the CFPB's contentions that the identified issues are occurring in the current marketplace.

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