As we reported, apparently unbeknownst to Director Cordray, the CFPB began taking complaints about student loans and vehicle and other consumer loans on March 1. While announcing the opening of its student loan system on the home page of its website, the CFPB’s first mention of the launch of its complaint system for vehicle and other consumer loans appears to be an item posted on March 12 on the CFPB’s blog.
According to the post, the only complaints the CFPB is currently handling directly are complaints against large banks. Complaints involving a small bank or a nonbank will be referred “to another federal agency with the authority to handle it,” which presumably means a prudential regulator for a small bank and the FTC for a nonbank. The CFPB shares enforcement authority over most nonbank consumer lenders with the FTC (other than auto dealers who routinely assign retail installment sales contracts or leases to unaffiliated third parties.) However, the CFPB apparently has a particular interest in nonbank auto lenders, since it states that “over time” it plans to develop the ability to directly handle complaints against nonbank auto lenders. We expect that among the auto loan complaints received by the CFPB will be complaints against auto title lenders since many consumers are likely to view a title loan as an “auto loan.”