Consumer Financial Protection Act
In 2010, Congress passed the Dodd-Frank Reform Bill and the Consumer Financial Protection Act (CFPA)creating the Consumer Financial Protection Board which has been given certain regulatory responsibility and investigative oversight of consumer transactions, primarily in the mortgage industry. While the provisions of this law may not be relevant to auctions involved exclusively in wholesaling to institutional purchasers, some ServNet auctions may have direct dealings with consumers, particularly in regard to sales of repossessed vehicles. For such transactions, auctions may want to consult with counsel as to the applicability of provisions of the CFPA and the authority of the Board.
For those auctions who do engage in consumer transactions, the International Automotive Remarketers Alliance (IARA), as a resource, has prepared a form to consult as a guide and/or checklist for certain day-to-day activities.
Auctions should consult with their executive leadership and counsel to assess the usefulness of this form to individual business and its needs. ServNet values its relationship with IARA and is providing access to this form at IARA’s suggestion.