By on September 30, 2014

CFPB - Consumer Financial Protection Bureau Sign

The hammer has fallen on captive automotive lenders, such as GM Financial, Ford Motor Credit and Toyota Financial Services: The Consumer Financial Protection Bureau began officially asserting its authority over them as the feds and the lenders battle over allegations of discrimination in the latter’s loan products.

Forbes reports the captives — regulated at the state level until this month — will be used indirectly by the agency to regulate dealerships as far as financing is concerned; the new-car dealer lobby won exemption from oversight in 2010.

The focus? Dealer reserve. Lenders allow dealers to add a few percentage points to the former’s loan packages as compensation for generating the leads, generally capped between 2 to 3 percentage points by most lenders. However, the allegations claim dealerships use their dealer reserve to charge more on loans made to protected classes, such as women and minorities.

The CFPB plans to address the issue by “pushing lenders to switch to some form of dealership compensation that takes away dealer discretion, such as a fixed, flat rate for every customer.” The agency also suggested lower caps could also do away with the alleged variations in dealer pricing.

For its part, the National Automobile Dealers Association claims competition “keeps rates low,” that dealership compensation is lower than the rate caps suggested, and by moving to a fixed, flat rate with even lower caps, dealers would no longer be able to offer discounts on financing.

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51 Comments on “CFPB Brings The Hammer Down On Captives, Dealer Reserve...”


  • avatar
    skor

    I think the Consumer Financial Protection Bureau would better serve the public by discouraging auto loans that look like mortgages. I recently read a story about a man who owed $89K on a Porsche.

    .northjersey.com/news/business/ramsey-luxury-car-dealer-s-license-suspened-1.1096456

  • avatar

    Long overdue.

  • avatar
    highdesertcat

    Meh, this is just the captive automotive lenders. What is going to be done about the other discriminiatory lenders, like those that exclude financially sound old people?

    What would be a step forward would be to have lenders extend auto loans to financially sound old people under the same conditions and criteria as they do to 25-year old borrowers.

    But it is unlikely lenders or the CFPB will do that because they fear the old people will die before paying off the loan and then the lenders will be stuck with litigation of estate settlements. That can take years to settle.

    • 0 avatar

      Hi HDC,
      Your situation reminds me of an old grandmother from my neighborhood. She was a depression era, fine midwestern, salt of the earth, sharp as a tack, tough old broad, kind of lady, who back during the Bush Ownership Society days would fill out all the credit card applications that came to her in her mailbox, and then pass them out to her many children and, grandchildren as gifts. I think she just paid the minimum balance, and when she passed, I have no idea how much she took the banks for.
      May God bless her.

      • 0 avatar
        highdesertcat

        crazycarlarry, I didn’t want to bring that up but a lot of old people are resorting to just that these days, and just paying the minimum due on those credit cards until they croak.

        That scheme has been around for many, many decades. And it works very well. Close to home, my wife’s dad, at age 88, has been doing it for many years; handing out credit cards as gift cards to his grand kids and great grand kids. I could tell you stories that would make lenders’ toes curl.

        But it doesn’t have anything to do with cars….

        Except….., that this past Wednesday he bought and paid for in full a 2015 Sequoia Platinum for my wife (his daughter) since she will be taking over the operations of the family real estate business effective tomorrow, when her parents retire and eventually move back to Germany (where they came from in 1946).

    • 0 avatar
      dal20402

      Why is the risk of high out-of-pocket costs due to estate litigation any different from other lending risks? Why shouldn’t lenders consider that risk?

      Every time you prohibit a lender from considering a given risk, it increases costs for all borrowers. Any such rule is effectively a subsidy to those it benefits. Do we really need to subsidize rich old people at the expense of all other borrowers?

      • 0 avatar
        highdesertcat

        dal20402, seems to me the rich old people are subsidizing everyone else, because they’re rich.

        Seems to me that fairness in lending is the least we can do for rich old people who want to preserve their personal wealth to pass on to their heirs.

        In case you’re wondering, I’m NOT rich! In fact my income is so low I don’t even have to file an income tax return and haven’t filed a tax return since 1985 when I retired from the Air Force.

        • 0 avatar
          VoGo

          HDC,
          You see rich elders subsidizing the young, whereas younger people who work see so much of their paychecks going to pay Social Security taxes. That’s a huge inter-generational wealth transfer.

          • 0 avatar
            highdesertcat

            VoGo, my comment has disappeared into the vastness of the ttac server universe.

            And reposting with my copy returns “Looks like you already said that”

            Sorry

        • 0 avatar
          krhodes1

          @HDC

          As you well know, income and wealth are two entirely different things. My Grandparents are quite wealthy, but I know exactly what their income is as I do their taxes – not a whole lot. Warren Buffet also has very little taxable income…

          Stop being disingenuous. :-)

          Personally, I plan to die with as much debt as I can possibly handle. I can’t take it with me, and the banks can fight over the scraps!

          • 0 avatar
            highdesertcat

            krhodes1, your comment brought a smile to my face because you have illustrated time and again with your sage comments that you understand that in life it is not how much you make that matters.

            What matters is how much you get to keep.

  • avatar
    DeadWeight

    Idiotic.

    95% of the time that government attempts to remedy a perceived (or real, for that matter) wrong in the market, their actions only lead to a cascade of complications, additional costs, bureaucratic ineptitude, higher transaction costs for the majority of consumers, and in general, a giant, steaming mess.

    The free market is the best antidote for alleged “rate gouging;” let intelligent consumers aggressively shop interest/finance rates, and let unintelligent ones not do that. That’s what markets do.

    Then again, at least with GM, they were a ward of the state up until very recently, and wouldn’t exist today based on the (in)competency of their management structure and shoddy products, had it not been for big government interference with markets,’so…

    • 0 avatar
      skor

      You betcha, I’m sure free market solutions will work to solve the problems of murder and rape as well.

      You really need to pull your head out of David Koch’s ass.

    • 0 avatar
      dal20402

      LOL. I suggest you do some research on the foibles of banking from the 1890s to the 1920s before coming here and arguing that an unfettered free market is good for banking consumers.

      Hint: Banks are big. They can afford staffs of lawyers and professional wordsmiths who drown consumers in elaborately written, deceptive copy. Consumers can’t afford their own staffs of lawyers to figure out what that copy actually means.

      In the mortgage arena, the most important and successful regulation we’ve had to date is the Truth in Lending Act disclosure requirements. Now every consumer gets a standardized, (relatively) easy-to-read disclosure before signing a mortgage agreement. Do you really think that would happen without TILA and the regulations under it?

      • 0 avatar
        IHateCars

        ….and with Binding Arbitration agreements on almost everything we buy, the consumer is almost always guaranteed the short end of the stick from arbitrators that the offending bank/company hires.

        But, hey…Tort Reform and all that…

    • 0 avatar
      DeadWeight

      This has nothing to do with legalise, or indecipherable & lengthy document language. It deals with what are essentially payments made to dealers by lenders for leads that turn into loans to people to finance automobiles.

      1. Why must there be “a fixed, flat rate (for payments made to lenders by dealers) for every customer?”

      2. If someone doesn’t like the rate they are being charged by the new car dealer on their financing, and they suspect (or know) that they’re being assessed a premium because of their gender or race, why can’t they obtain a loan from elsewhere, such as a credit or bank of their own choosing?

      • 0 avatar
        VoGo

        DW,
        I’m a fan of yours, and typically favor market-based solutions.

        But what is going on here is not simply that those who are not market savvy are being taken advantage of. Studies has show that the people who are getting screwed by the F&I process tend to be poor, black, female and minority.

        Tell you what — we’ll send you to 5 dealerships on Saturday and have you bargain for car. Then have an elderly black woman go to the same dealerships and try to buy the same car. Do you have any doubt that you would save mega $ on every transaction? I don’t.

        I am not a fan of inventing new regulation for every problem. Good education for buyers who are discriminated against by the F&I process and the usual tricks would certainly be a better start.

        But if that isn’t sufficient, then I think it’s unAmerican to sit back and watch as our most vulnerable citizens are discriminated against and preyed on.

        • 0 avatar
          DeadWeight

          Dealerships are scumbag entities, for the most part.

          Minorities have been shafted by the least ethical businesses in the world, such as auto dealers, title/pawn shops, rent-a-centers, etc. forever.

          Many of these same people could easily shop around, taking advantage of lower rates offered by credit unions or other lending institutions, and essentially deny the dealership the padding that is the bundled financing derived from the vehicle sale, if they chose to do so.

          The “points” the dealer is picking up from the lenders whom they steer business to essentially jacks up the overall finance rate and/or loan service costs for the customer.

          The proper response to this issue is for consumers to do their homework, shop rates and be aggressive when buying the 2nd most expensive item most people will ever purchase in their lives.

          The answer is not for more government agencies to be created and/or more governmental regulations to be propagated.

          Barring developmental disabilities, senility, mental illness, etc. that is typically a bar to contract in the first place, should the government attempt to prevent mentally competent adults from voluntarily entering into deals with higher transaction costs than otherwise could be the case?

          • 0 avatar
            Astigmatism

            “Minorities have been shafted by the least ethical businesses in the world, such as auto dealers, title/pawn shops, rent-a-centers, etc. forever.

            Many of these same people could easily shop around, taking advantage of lower rates offered by credit unions or other lending institutions, and essentially deny the dealership the padding that is the bundled financing derived from the vehicle sale, if they chose to do so.”

            By which logic, why should we have the Civil Rights Act when there are plenty of other lunch counters that minorities could eat at?

            “Should the government attempt to prevent mentally competent adults from voluntarily entering into deals with higher transaction costs than otherwise could be the case?”

            Considering that financial conglomerates spend tens of millions of dollars hiring lawyers and consultants to advise them on how to get mentally competent adults to voluntarily enter into deals with higher transaction costs than otherwise could be the case: yes.

          • 0 avatar
            krhodes1

            @Deadwieght

            Yes.

      • 0 avatar
        dal20402

        1) Because the current practice provides an incentive for dealers to take advantage of the least informed consumers.

        2) Because when a market is composed of a few very large players, which the lending industry increasingly is, product offerings tend to converge and there is rarely any choice. We are already there in the credit card market and a few more small-bank failures will get us there in the auto lending market.

        • 0 avatar
          Landcrusher

          So, why isn’t the solution to better inform minorities and women? Wouldn’t it likely be cheaper and easier to put out a report showing the findings and encouraging people to show up with a loan in pocket?

          And let’s not blame the banks here. I have plenty of loathing for banksters in general these days, but this is a guy working for a state mandated oligopoly – an auto dealership. The dealership sells cars made buy another oligopoly which is virtually state protected sense the cost of entry due to regulatory barriers is huge.

          Throw labels and hate all day, but there is no denying that this problem has nothing at all to do with a free market. It’s about a regulated financing of a regulated product.

    • 0 avatar
      jim brewer

      The hell it is dead weight. We have decades long history of predatory and discriminatory loans. You can argue all you want that the market is self-correcting, but the fact is, it is not.

      • 0 avatar
        Landcrusher

        Jim,
        Perhaps an economist will comment, but I’m not sure from an economics point of view that the market isn’t actually working. We all may just not like the results.

        Let’s note that the market is not free, but actually quite regulated. It’s regulated with a prejudice that more car loans are a good thing for starters.Then, let’s question the findings. To what degree is the data simply reflecting the reality that minorities and single women are less informed and less able to pay? One of the most important functions of markets is to give us information, but you have to read the information it gives you and interpret it correctly.

        I’m still at a loss as to why the government response here isn’t education rather than threats.

    • 0 avatar
      danio3834

      I’m with DW on this one. If a person doesn’t fully understand the contract they have in front of them, they shouldn’t sign it. If there’s actual fraud taking place in the contract, then let “the hammer” fall on them for that.

      Fixed and/or flat rates for everyone basically forces good credit customers to take a hit for the sake of the bad ones. Is a car loan a right that is now enshrined to every American?

      • 0 avatar
        DeadWeight

        1) Your point about good credit customers being penalized (subsidizing poor credit customers) by these idiotic regulatory edicts is spot on.

        2) The point made above that the “market” is already fixed to create/originate as many loans as possible is spot on.

        3) Danio, I am not even claiming fraudulent clauses in a contract should be enforceable (they’re not; they would either be unenforceable if they were legally fraudulent, or they would invalidate entire contract). I am merely claiming mentally competent adults signing contracts should be bound by the terms of those contracts, whether they could/should/would have gotten better deal by doing more shopping around and/or choosing different dealer/lender etc.

        This agency wants to create a “fairness in pricing” standard, impose it across the board, and police the price terms in contracts? WTF?

      • 0 avatar
        DeadWeight

        1) Your point about good credit customers being penalized (subsidizing poor credit customers) by these idiotic regulatory edicts is spot on.

        2) The point made above that the “market” is already fixed to create/originate as many loans as possible is spot on.

        3) Danio, I am not even claiming fraudulent clauses in a contract should be enforceable (they’re not; they would either be unenforceable if they were legally fraudulent, or they would invalidate entire contract). I am merely claiming mentally competent adults signing contracts should be bound by the terms of those contracts, whether they could/should/would have gotten better deal by doing more shopping around and/or choosing different dealer/lender etc.

        This agency wants to create a “fairness in pricing” standard, impose it across the board, and police the price terms in contracts – ???

  • avatar
    Jerome10

    While I’m no fan of forcing non-discrimination rules upon on private businesses (even if I personally disagree with their actions) , if I am understanding this correctly, the dealerships have discriminated, correct? Not the financial companies?

    If so, should the dealerships not be prosecuted under existing laws and that’s that?

    All I see here is more meddling, trying to force “fairness” on everyone. Just leading to more costs for those who normally would be offered more attractive rates.

    At what point will running credit checks be discrimination? Everyone must pay the same rate regardless of ability to repay the loan!

    Sounds a little like how college loans are handled… Have a pulse? Get 100k in student loans for that art degree….

    Meddling in things like this is how we have gotten so messed up financially in this country.

    Also, how does this game work. Wouldn’t this dealer money be able to be used to get people lower rates by passing on some of this payment from the lender to the buyer?

    Really need more info here and stats to understand if they really are doing this. Though my point about it being dealer discrimination still stands.

    • 0 avatar
      VoGo

      Jerome,
      You make a good point about the dealers being the source of the discrimination. But the CFPB lacks the jurisdiction to regulate dealers; financial companies are their focus.

      To prosecute dealers for discrimination would require that local governments act against the dealers who typically are large campaign contributors to local political campaigns.

      So, we know how that story ends.

      • 0 avatar

        No, it would NOT require local governments to act against auto dealers. Local government has little or nothing to do with the issue. It isn’t even required that dealers actually discriminate for their lenders to be “punished.” There is no action available to CFB to get at auto dealers so they go after their lenders.

        BHPH dealers are an exception. They fall under CFPB auspices.

    • 0 avatar

      RE: “Meddling in things like this is how we have gotten so messed up financially in this country.”

      HUH? The CFPB is engaged in gratuitous over reach in their attempt to go around Congress intent and attack car dealers, but it was a LACK of regulation that got us “messed up financially in this country.”

      • 0 avatar
        Landcrusher

        Convenient how you ignore that this is a regulated financing of a regulated product at a dealership whose existance is mandated by state law.

        Let’s be real. None of this is due to lack of regulation. It’s due to poor regulation which is inevitable when there is too much of it.

        Why isn’t there any thought to going into the mounds of regulation and figuring out if all the regulations aren’t really the source of the problem already? Really.

        Don’t assume they are not. There are all sorts of incentives and disincentives unknowingly created in all that refuse.

  • avatar

    The “Hammer” has NOT fallen on the lenders mentioned. The “Hammer” HAS fallen on Ally Financial, which was assigned fines and retribution of about $98 million in a successful extortion by CFPB months ago just when Ally was ready to go forward with their IPO to raise funds to buy out the government (taxpayers). The government fined themselves.

    RE: “Lenders allow dealers to add a few percentage points to the former’s loan packages as compensation for generating the leads, generally capped between 2 to 3 percentage points by most lenders.”

    A FEW? Why say “a FEW” and then come back with “capped at 2 – 3 percentage points?”

  • avatar

    http://autosandeconomics.blogspot.com/search?q=CFPB

  • avatar
    Kendahl

    When I need to finance an automobile purchase, I shop around for the best interest rate. Depending on who was hungriest, I have gotten loans from banks, S&Ls and credit unions. One time, I humored a dealer by letting him go through the motions of quoting a rate. It turned out that his rate, with a local bank, was lowest of all.

    I don’t understand why it should be so hard for others to do the same. All that matters is the lowest interest rate. It’s even simpler than asking competing dealers for their best prices on a specific model and set of options. The latter can get complicated when dealers make offers on vehicles in stock that have different options.

    What I hate worst about buying a car is the time I must waste telling everybody that follows the salesman to shove their extended warranties, paint protection, prepaid maintenance, etc. up their asses.

    • 0 avatar
      krhodes1

      But you presumably have very good credit, are educated about how credit works, and can be pretty certain you will be approved about anywhere.

      Now imagine you are less educated, have poor credit, and just need a new or new to you car. The dealer CAN get you financed, it is just a matter of how much it will cost you. Maybe a fair rate is 8%. But because the dealer feels they can get away with it, they charge you 10% or 11% – lender gets 8%, they get the difference. You will probably take it and not even realize you are getting screwed by a 20-25% markup on the financing. I really don’t have a problem with banning this practice. If your fairly rated credit means you should pay X, you should pay X no matter who you are. Not X + 3% just because you are woman, or black, or young and naïve.

      • 0 avatar
        28-Cars-Later

        I don’t know if the allegations are true but if they are its simply stupid because you can screw every buyer out of that three percent and no one in a position of oversight would question it. What may be happening is additional screw you fees attached to exceptionally low credit score loans, but again you call it a “low credit” fee and hit everybody. We’d need more information to make a better assessment.

  • avatar
    George B

    I could see the CFPB requiring the lender to disclose to the end consumer the compensation arrangement to the dealer. Sort of like how buyers now have some information about invoice pricing and holdback, but dealers sill have flexibility to charge a higher out-the-door price. Disclosure makes it a little easier to find the market price, but in the end the customer has to ask for bids and negotiate a little to get to the final price.

  • avatar
    Xeranar

    I don’t care to push into this crowd but I shall offer a simple view. What business is it of the dealership to get interest on a loan they do not own or have any interest in? A dealership is paid by the bank for the product I buy. It is in their business interest to help me finance a product for convenience. So why exactly is giving them 1-3 percentage points part of the transaction cost?

    Regardless of the ‘shop around’ mentality which is flawed because of the inherent nature of monopolization and cartels (which they banter about frequently but fail to understand the terminology) the system should never have rewarded them with points in the first place. A flat fee should have been sufficient and they should have been thankful for that since ultimately the citizen is the one paying for these even as the businesses give each other profit on the back end.

    • 0 avatar
      28-Cars-Later

      This behavior has been going on for some time, banks used to give a several hundred dollar bonus ($400-600 IIRC) to my dealer when a loan was sold through them (PNC comes to mind). Whether these were points on the loan I honestly cannot be sure because I wasn’t doing F&I. I was under the impression this was an incentive from the bank to use them over their competitors, and it had nothing to do with “protected classes” the bonuses were based on the loan amount and which bank was used. This bonus was among a number of variables which determined the final price, along with trade and any negotiating by the buyer. I’m not sure what’s going on in the industry today, but its possible the “protected classes” are engaging in loans for product they cannot afford more frequently and are perhaps getting clobbered on interest due to credit history, but I am only speculating.

      • 0 avatar
        highdesertcat

        I agree with 28-Cars-Later. I have known this behavior to be Standard Operating Procedure (SOP) for the more than 30 years that my four brothers were in the multi-brand new and used car retailing business.

        It’s business as usual for most dealerships and there are tons of money to be made from kickbacks, preferential lending referrals, preferential insurance referrals, etc.

        In many cases, the bonus that 28-cars-Later refers to, offset the commission the dealer had to pay the salesman and/or bird-dogger.

        One way to get around all that is to pre-arrange your own financing and insurance through a reputable shareholder-owned credit union like NavyFed or Pentagon FCU, or USAA.

        Dealers HATE that because they can’t make any money on that arrangement.

        • 0 avatar
          krhodes1

          @HDC

          Don’t they though – the F&I guy at the dealership where I bought my Saab in ’09 nearly scuppered the deal being such a pill over the fact that I had my own pre-arranged financing. All I needed was the official amount for the check so I could have it cut, drive down, and pick up the car (it was 125 miles away). F&I guy dragged it out for hours. I finally called my salesman, told him he had 5 minutes to get me the number, or the deal was off, I was tired of talking to the douchebag.

          Then when I got there they kept me waiting for a few hours to sign the paperwork. Maddening, but I did get more than $13K off the price of the car, so worth a bit of hassle.

        • 0 avatar
          Xeranar

          I agree it is nice to be able to bring in your own financing. I did that with my parent’s help on my Scion and it took several hours to unravel the F&I guy to accept that. He even set the paperwork in front of us with their own higher percentage on it claiming it was our paperwork. For a time he even claimed he couldn’t process it for legal reasons, it was so hilariously stupid and would have genuinely been funny if it wasn’t just stress on my heart I didn’t need.

          I actually don’t want this to be combative with you HDC, but your response is normative. There isn’t a good reason I can see of why this is accepted practice except that it is essentially legal and the monopoly refuses to move on it. It sounds like a time for regulation to end the practice all together.

  • avatar
    el scotto

    The B&B are a pretty sharp bunch. They’ve been to the financing rodeo more than few times. What comes to mind is the car dealers advertising: “Got a job?, got a a few hundred dollars?; bring in two pay stubs and a utility receipt and we can get you into a new car!” The CFPB is looking to protect those consumers; the ones basically living paycheck to paycheck, and finacially not savvy. If the CFPB wanted to help (and use common sense) they should put some sort of “Places to get a car loan” kiosk/carborad display in every dealership. That should please both the fans of Rachel and Rush.

  • avatar
    kjb911

    Why isn’t the CFPB investigation the predatory lending of Buy Here Pay Here giants and the companies like Credit Acceptance Corp. Every time I have a customer come in with a loan from Credit Acceptance on a 2005 Malibu with 183K and a payoff of $12,322.00!

    One of the bigger buy here pay here around my area (Shannon Motors) has even begun offering leases on used cars. 455 a month for a 2008 Cobalt LS with 122K…yea that happened the other day/

    • 0 avatar
      28-Cars-Later

      Unconscionable.

    • 0 avatar
      krhodes1

      The problem is there has to be something actually illegal that they are doing. You can charge outrageous rates as much as you want, as long as you charge everyone FAIRLY. You can’t charge white guy with 500 credit score 15% and black guy with 500 credit score 22%. Or single Mom with 500 credit score 26%. But you can charge everyone 26%, if that is allowed in your state.

      I agree that the whole BHPH and paycheck loan industry needs a lot more scrutiny, but I also think the alternatives are probably worse. Better to pay too much or have your bad credit made worse than to have Guido break your legs.

      • 0 avatar
        Landcrusher

        Not that I really care anymore, but the credit scores are just stupid. If you want to mandate things based on the scores then the scores need to be utterly transparent and reflect only failure to pay. False claims of bad behavior need to be damages to be reclaimed in court. And finally, ability to pay needs to be a separate issue altogether.

        • 0 avatar
          Xeranar

          This I can agree with LC. The problem with credit scores now is that it isn’t just the big-3 who manage them. Most private insurers, lenders, and actors are producing their own ‘score’ based on the scores they receive and wholly proprietary market data. Race is certainly an issue within them, so is location, and education. You can have a PhD but live in a red-line district (like I do effectively in Pittsburgh) and you’ll be given higher interest rates by most groups.

          • 0 avatar
            Landcrusher

            Is there any proof of them using race as a data point or is this just something that somebody surmised? I would love to throw that sort of thing at my useless congressman.

  • avatar
    dwford

    The idea that dealership finance guys are discriminating against women and minorities and charging them higher rates than white males is ludicrous. They are discriminating against people who don’t realize they can negotiate the rate, and any finance guy would happily charge the rate markup to a white guy just like anyone else. That’s how they make their money. No finance guy is going to purposely make less just because a white male sits down in front of them.

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