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FTC Provides Enforcement Report to CFPB Covering Regulations Z, M, and E.

June 12, 2015 / Source: Ballard Spahr

The Federal Trade Commission has provided its annual Financial Acts Enforcement Report to the CFPB covering the FTC’s enforcement activities in 2014 related to compliance with Regulation Z (Truth in Lending), Regulation M (Consumer Leasing), and Regulation E (Electronic Fund Transfers).  Under Dodd-Frank, the FTC retained its authority to enforce these regulations with respect to entities within its jurisdiction.  The FTC and CFPB coordinate their enforcement and related activities pursuant to a MOU entered into in 2012 and reauthorized in 2015.

Reg Z/TILA.  The FTC’s enforcement activities included two actions for civil penalties involving alleged deceptive advertising by auto dealers filed in federal district court, nine consent orders settling deceptive advertising claims against auto dealers, and a stipulated order against a subprime auto lender charged with using illegal servicing and collection tactics.  Other TILA-related enforcement activities included actions against payday lenders, companies advertising mortgage loans (lead generators and a homebuilder), and companies providing mortgage assistance relief services (several of which involved forensic audit scams in which the providers offered, for a fee, to review or audit mortgage documents of distressed homeowners to identify legal violations).

Reg M/ Consumer Leasing.  The FTC’s enforcement actions included final consent orders with ten auto dealers to settle deceptive advertising claims.

Reg E/EFTA.  The FTC’s enforcement actions included five cases involving negative option plans, three cases involving payday lending, and one case involving retail financing.