b'the investigation is to determine whether LoanMartsChopra, has made public statements in the past urging role in the arrangement is such that it, rather thanthe FTC to do more to combat discriminatory intent and CCBank is the true lender, such that the loansdisparate impact in the auto lending industry.contravene the states usury caps. Third, the Biden administration has announced that COVID-19-relief measures will be a near-term priority. Looking Ahead to 2021Some industry observers have predicted that such relief may include a moratorium on vehicle possessions We expect auto lending to be a key focal point foruntil the crisis is over. There is good reason to believe federal and state regulators over the next couple ofthat federal agencies may make auto lending a years. On the federal level, the new administration willCOVID-19 relief priority: the CFPB reported a spike in likely take a more active role in the auto lending spaceconsumer complaints about auto financing since the for several reasons. First, two years ago, Congressstart of the COVID-19 pandemic. Consumers submitted invalidated the CFPBs Obama-era indirect auto lendingmore than 2,800 auto loan and lease complaints from bulletin, which stated that lenders offering auto loansMarch through July of 2020, more than any other five-through dealerships would be held responsible for themonth period throughout the eight-year history of the discretionary pricing practices of auto dealers whereConsumer Complaint Database. Complaints regarding those practices resulted in pricing disparities amongauto loan payment relief skyrocketed to almost consumers based on race, ethnicity, or national origin.300complaints filed between March and July of 2020, It is likely that the CFPB under the Biden administrationmore than double what was reported during the same will attempt to revive the bulletin in some fashion, even though under the Congressional Review Act re-implementing the prior rule would require an actBy the end of 2021 we anticipate an ofCongress. Second, Democratsincluding those most likely toincrease in federal enforcement activity place an active role in shaping the future of the CFPBacross the board and consumer-friendlyhave stated that discrimination in auto lending isagency guidance, proposed rules, and rampant. Elizabeth Warren recently criticized the CFPB for not having taken meaningful action to combatproposed legislation in a number of key these trends during [Director Kraningers] tenure.areas, including auto lending, mortgages, Further, Warren reportedly characterized auto loans as the most troubled consumer financial product.payday and small-dollar lending, and Similarly, President Bidens pick for CFPB Director, Rohitstudent lending. 50'