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Consumer Loans and Auto Loans: Disclosures are Key

In their June Monthly Complaint Report, the CFPB put the spotlight on consumer loans. The CFPB has received over 38,500 consumer complaints about consumer loans since 2011. The most commonly complained-about consumer loan product is auto loans, comprising about 60% of all complaints about consumer loans. 

While many of the auto loan-related complaints were about payment processing issues, a great deal of them involved UDAAPs (Unfair, Deceptive, and Abusive Practices), including deceptive marketing. Many consumers indicated lack of clarity over fees and high interest rates, as well as deception by misleading advertisements. The CFPB has demonstrated in previous auto cases that they will not tolerate these practices and will issue a hefty fine for companies that do not comply.

The CFPB is not the only federal regulatory agency keeping a close eye on auto lenders. Since last year, the FTC and 32 law enforcement partners have been cracking down on fraud and deception in the auto industry.

In fact the FTC put out very clear guidelines around disclosures and specifically those online in a bulletin.  The bulletin clearly outlines how to make effective disclosures in digital advertising and goes into detail on everything they expect from “clear and conspicuous disclosures” including: Proximity and Placement, Prominence, Distracting Factors in Ads, Repetition, Multimedia Messages and Understandable Language. 

The FTC also initiated Operation Full Disclosure back in 2014 where they sent warning letters to 60 of the top 100 largest advertisers in the country that failed to make adequate disclosures in their television and print ads. 

When it comes to protecting the consumer, inclusion of proper disclosures is key. Learn more about disclosures, how to protect consumers, and keep your brand compliant with federal marketing regulations with the PerformMatch™ platform.

 

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Tags: Regulatory Compliance

Understanding and complying with UDAAP policy can be a challenge

Download this guide to learn what every company should know to reduce exposure to Unfair, Deceptive or Abusive Acts and Practices (UDAAPs) and other common compliance violations.

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