Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 3216 ups.” The agencies alleged, based largely on question- able data analysis techniques, that these discretionary markups caused minority borrowers to pay, on average, $200 more for their auto loans. Indirect Auto Lender Settles Advertising and Debt Col- lection Claims for $48 Million. On October 1, 2015, the CFPB and an indirect auto lender, Westlake Services, LLC and Wilshire Consumer Credit, LLC, settled allega- tions that it violated the Fair Debt Collection Practices Act (FDCPA), TILA, and the Dodd-Frank Act by decep- tively advertising interest rates and using deceptive debt collection practices, such as using fake caller identifica- tion information and disclosing or threatening to disclose debts to borrowers’ family, friends, and employers. Looking Ahead to 2016 The CFPB likely will exercise its recently expanded regu- latory authority over auto lending in 2016, but Congress may attempt to repeal or otherwise constrain that author- ity. The CFPB has further proposed rulemaking on auto lending, and rules are set to be released for notice and comment in the first quarter of 2016. Meanwhile, a bi- partisan bill in the U. S. House of Representatives (H.R. 1737) is currently being considered in the U. S. Senate which, if enacted, would curtail the CFPB’s authority to regulate auto finance. The CFPB and DOJ, armed with the U.S. Supreme Court’s recent validation of “disparate impact” liability in mortgage discrimination cases under the FHA, will continue to advance cases against indirect auto lenders under ECOA based on dealer mark-up, dealer participation and total price. Using the play book from its credit card add-on product cases, the CFPB will further heighten scrutiny of auto add-on products, such as gap insurance and extended warranties. What to Watch Congress may attempt to curtail CFPB authority over auto lenders | Continued focus on indirect auto lenders | Heightened scrutiny of add-on products PAYDAY LENDING MORTGAGE CREDIT CARDS AUTO LOANS TELEPHONE CONSUMER PROTECTION ACT FEDERAL COURTS OF APPEALS CONSUMER FINANCIAL & PROTECTION BUREAU STUDENT LENDING DEBT COLLECTION DATA SECURITY