b'period in 2019. The CFPB has also stated that autothe new California DFPI has much broader authority loan servicing will be at the top of the CFPBs list ofover the auto lending industry, including the authority prioritized assessments. The CFPB plans to conductto bring enforcement actions for alleged violations of targeted examinations into the products and practicesall California and federal consumer financial protection of each industry designated for prioritized assessment.laws that apply to auto lenders. Some California Under the Biden administration it is likely that CFPBassembly-members have called for quick action by investigations and enforcement will be more robustthe DFPI to address what they view as predatory loan and that remedies will be more aggressive. The Bidenpractices in the auto finance industry. administration has made clear that providing relief toThus, we predict an increase in enforcement activity consumers who have been economically impacted byrelated to the auto lending industry in 2020, both at the the COVID-19 pandemic will be a top priority. To that end,federal and state levels. many predict that federal agencies will focus on auto repossessions, potentially even placing a moratorium on vehicle repossessions in the coming year. What to WatchThe industry may also face renewed interest at theNew federal guidance and/or investigations related state level. Though states have always been theto dealer markups/discretionary pricing practices. primary actors in the auto-finance enforcement space, auto lenders doing business in California are likely toHow the DFPI exercises its new authority over auto face increased scrutiny. Though the former Californialending enforcement.Department of Business Oversight could investigate state-licensed auto lenders for certain alleged violations of Californias usury limits and licensing laws, 51'