April 2015 -- Effort to Stop Oregon BHPH Restrictions Succeeds
March/April 2015 -- NIADA, BHPH Commission, Oregon IADA Fight Restrictive Oregon Bill
December 2014 -- See comments NIADA filed with the CFPB on their proposed larger participant rule for the automobile financing market.
There are three things that we highlighted:
- We encourage the CFPB to consider a threshold of 50,000 originations in a calendar year, as opposed to 10,000, but definitely not 5,000 – a number they once considered. Any non-bank entity engaged in lending to consumers for purchase/leasing an automobile, refinances an automobile loan, or acquires those loans will be subject to supervision if they originate more than 10,000 a year. We suggest that 50,000 is a more appropriate number.
- We encourage the CFPB to not include automobile title lending in the definition of automobile financing as it is a separate financial product.
- We challenge the CFPB on their attempt to distinguish BHPH dealers from other automobile lending sources. We are glad BHPH dealers are exempted from this rule, but we challenge the CFPB’s reservation of rights to pass a BHPH specific rule in the future.