CFPB Bulletin on Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act

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Federal Reserve Bank of San Francisco

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April 5, 2013

On March 21, 2013, the Consumer Financial Protection Bureau (CFPB) issued CFPB Bulletin 2013-02 on indirect auto lending and compliance with the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B. While the bulletin is directed at institutions under the CFPB’s jurisdiction, the guidance is consistent with the Federal Reserve’s existing position on the applicability of the ECOA to indirect lending programs. As a result, the CFPB’s bulletin is a good reminder for all those engaged in indirect auto lending.