Association of Insurance Compliance Professionals Gulf States Chapter E-Day 2014

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1 Association of Insurance Compliance Professionals Gulf States Chapter E-Day 2014 Consumer Financial Protection Bureau s Encroachment into the Insurance Industry What You Need to Know June 13, 2014 Brian T. Casey, Esq. Partner, Co-Chair Regulatory & Transactions Insurance Practice Group

2 Presentation Overview Overview of Consumer Financial Protection Bureau Treatment of Service Contracts/Extended Warranties, GAP Waivers and Ancillary Products for CFPB purposes Auto Dealers Exemption from CFPB and CFPB s interest and enforcement actions in indirect auto lending CFPB s encroachment on Insurance Products

3 CFPB Overview Established by Title X of Dodd-Frank Act Wall Street Reform and Consumer Protection Act of 2010 and created in 2011 to address widespread failures in consumer protection and rapid growth in irresponsible lending practices. New independent federal agency within Treasury Department but fairly autonomous Single Director appointed by President and confirmed by Senate for 5 year term, Richard Cordray Former Ohio Attorney General Recess Appointed by President in 2012 following Elizabeth Warren s departure as de facto initial Director Confirmed by Senate in July 2013, but had acted in limbo initially because of Senate confirmation blockage threat and questionable appointment based on Canning v. NLRB recess appointment case

4 CFPB Constitutional Challenges State National Bank and 11 AGs v. CFPB, Treasury Dept., SEC et al. separation of powers case dismissed by D.C. District court for lack of standing in August 2013, but appeal has been filed Pisinski and Morgan Drexen v. CFPB (D. Ct., D.C.) filed in July 2013 by bankruptcy lawyer and debt relief services firm that supplied paralegals in response to CFPB s Civil Investment Demand and alleges separation of powers violation and challenge to CFPB s threat of Telemarketing Sales Rule enforcement action; CFPB obtained motion to dismiss in October 2013, but appeal has been filed CFPB v. Morgan Drexen (D. Ct., C.D. Cal.) countersuit filed by CFPB alleging TSR and UDAAP violations for MD s collection of upfront consumer fees

5 High Level of CFPB Political Friction Deep Partisan Congressional Divide over CFPB Single Director s power concentration v. multi-member council structure like FSOC and SEC Budget process and free-spending Budget: FY 2013 ($541mm); FY 2014 ($497mm) Outside of Congress appropriations process for agency independence, but cap of 12% of the Federal Reserve s operating expenses About 1,300 employees

6 CFPB Powers & Duties Regulations FSOC can review and overturn Consumer financial education Monitor financial markets for new risks to consumers Consumer complaints collection Examinations/Investigations Civil Investigative Demand Civil penalties (fines, disgorgements and restitution) Criminal Referrals to DOJ and other federal agencies

7 CFPB Focuses Directly on consumers, rather than safety and soundness of providers of consumer financial products/services or monetary policy Heighten government accountability by consolidating in one federal agency responsibilities that had been scattered across federal government Exercise responsibility for supervision and enforcement of consumer protection laws for providers of consumer financial products/services that escaped regular Federal regulatory oversight Unfair, Deceptive or Abusive Acts and Practices ( UDAAP )

8 Laws Inherited by CFPB Electronic Fund Transfer Act (mostly) Equal Credit Opportunity Act Fair Credit Reporting Act (mostly) Fair Debt Collection Practices Act Consumer Privacy Truth in Savings Act Section 626 of Omnibus Appropriations Act, 2009 (mortgage advertising; foreclosure and modification scams) Supervision of non-insured depository institutions Consumer Leasing Act

9 Laws Inherited by CFPB Mortgage Loan Related Laws: Truth in Lending Act ( TILA ) Home Mortgage Disclosure Act ( HMDA ) Real Estate Settlement Procedures Act ( RESPA ) S.A.F.E. Mortgage Licensing Act Mortgage Advertising Rule (Regulation N) Alternative Mortgage Transaction Parity Act of 1982 Home Owners Protection Act of 1998 ( HOPA ) Home Ownership and Equity Protection Act of 1994 ( HOEPA )

10 CFPB s Core Powers Supervisory Authority which includes power to examine and require reports from large (more than $billion assets and other designated, large non-bank) persons CFPB supervises to: assess compliance with Federal consumer financial laws obtain information about such persons activities and compliance systems and procedures detect and assess risks to consumers and of consumer financial markets Enforcement Authority which allows CFPB to use its arsenal of enforcement powers against an entity that has violated one of CFPB s inherited areas of jurisdiction or committed a UDAAP

11 Sources of CFPB Enforcement Action Supervisory Exams Consumer Complaints state of the art call center and information handling systems Agency statement on whistleblowers being given top priority Cross-referrals from and joint initiatives with other federal agencies, including the FTC, DOJ, and HUD Cross-referrals from and joint initiatives with the State Attorneys General Market Data Research

12 CFPB s Enforcement Remedies Rescission or reformation of contracts Refund of money or return of real property Restitution Disgorgement of compensation for unjust enrichment Payment of damages or other monetary relief Public notification regarding violations Limits on activities or functions of person against whom action is brought Civil money penalties: $5,000 per day for violation of a rule imposed by CFPB $25,000 per day for reckless violation of federal consumer protection law, and $1,000,000 per day for knowing violation of federal consumer financial law

13 Unfair, Deceptive or Abusive Acts and Practices UDAAP In addition to authority to enforce laws it has inherited, Dodd-Frank Act gives CFPB catch-all authority to restrict unfair, deceptive, or abusive acts or practices through regulation and enforcement UDAP standard is partially provided by FTC Act and State UDAP statutes, but Dodd-Frank Act added term abusive, which may lead to more expansive interpretations regarding covered activity CFPB considers unfair, deceptive, and abusive as 3 separate terms, each with its own meaning to be determined Congressional and industry concerns that standard will be interpreted subjectively by CFPB

14 Traditional UDAP Standard Unfair an act or practice is unfair if it: Causes or likely to cause substantial injury to consumers Cannot be reasonably avoided by consumers; and Not outweighed by countervailing benefits to consumers or competition Public Policy may be considered with all other evidence Deceptive an act or practice is deceptive where: Representation, omission or practice misleads or likely to mislead consumer Consumer's interpretation of representation, omission or practice is considered reasonable under the circumstances Misleading representation, omission, or practice is material

15 New Abusive Term CFPB may declare an act or practice abusive if it Materially interferes with consumer s ability to understand a term or condition of a consumer financial product/service; or a lack of understanding on consumer s part of material risks, costs or conditions of product/service; or inability of consumer to protect his/her interests in selecting or using a consumer financial product/service; and reasonable reliance by consumer on a covered person to act in interests of consumer Term will likely be defined by CFPB s enforcement actions (we ll know it when we see it)

16 Consumer Financial Products/Services 10 enumerated types of consumer financial products/services primarily for personal, family or household purposes, which DON T include Insurance or service contracts/extended warranties. Extending credit and loan servicing Extending/brokering real/personal leases with purchase financing functional equivalency Real estate settlement services Check cashing, collection or guaranty services Payments or financial data processing services Financial advisory services not SEC regulated Consumer reporting agency Consumer debt collection Deposits, transmitting or custodian of funds Stored value/payment instruments

17 Firms under CFPB s Jurisdiction Large depositories (more than $10 billion in assets) Lenders and loan services, including mortgage-related businesses, payday lenders, automobile lenders and private student loan providers Loan originators and acquirers, purchasers, sellers and brokers Sellers, providers, and issuers of stored-value instruments Businesses engaged in check cashing, collecting and guaranty services Payment processors Others such as credit reporting services and debt collectors Service providers to any of the above persons

18 Service Provider under CFPB s Jurisdiction Service Provider is person that provides material service to a covered person in connection with offering or provision by covered person of consumer financial product/service, including: participating in designing, operating or maintaining consumer financial product/service; or processing transactions relating to consumer financial product/service Exceptions: support service of a type provided to businesses generally or a similar ministerial service; and time or space for an advertisement for consumer financial product/service via print, newspaper or electronic media

19 Key Exemptions from Consumer Financial Products/Services Business of Insurance because of McCarran-Ferguson Act s preservation of state regulation of insurance (for now at least) Auto Dealers predominantly engaged in sale and servicing of autos, leasing and servicing of autos, or both Securities regulated by SEC or state securities commission

20 Potential for Expansion of Consumer Financial Products/Services CFPB by regulation can add new consumer financial products/services if: purpose of product/service is to evade federal consumer financial law; or product/service can be offered by bank or financial holding company under federal law and likely to have material impact on consumers CFPB has not yet exercised this authority

21 Potential for Expansion of Consumer Financial Products/Services to SC/EWs? Are SC/EWs insurance products and thus under the Business of Insurance Exemption? Well, ahum, maybe yes for CFPB purposes, but surely not for state insurance law purposes SC/EWs of 3rd party obligor would be insurance but for their deregulation as true insurance products Predominantly regulated within state insurance codes, with a few exceptions like CA and TX But, some SC/EW laws wholesale exempt these products from being insurance, while other states retain limited applicability of certain insurance code statutes. Relevancy of McCarran-Ferguson Act s body of law on what constitutes the Business of Insurance? GAP waiver is likely not within the Bureau of Insurance exemption

22 How CFPB Can Regulate SC/EWs? CFPB could attempt indirectly to regulate SC/EWs and Ancillary Products: Regulation Z where lenders finance purchase of SC/EWs Unfair, deceptive or abusive sales acts or practices prevention authority where lenders or their affiliates sell SC/EWs Treating issuers of SC/EWs as Service Providers of lenders that finance purchase of SC/EWs (e.g., Dealers Financial consent order)

23 Auto Dealers Exemption from CFPB s Authority Auto dealers, many of which sell VSCs and Ancillary Products, have a specific exemption from CFPB CFPB cannot exercise rulemaking, supervisory, enforcement or other authority over auto dealers, except if: Providing consumers services related to residential or commercial mortgages or self-financing transactions involving real estate; Extending directly to consumers retail credit/leases for autos and credit/lease is not routinely sold in secondary market; or Providing consumer financial product/service not involving sale, financing, leasing, rental, repair, refurbishment, maintenance or other servicing of autos, auto parts, or any related or ancillary product/service

24 CFPB and Auto Dealer Finance Space CFPB is very interested in indirect auto financing and actively investigation several large banks. Generally, franchised auto dealers are outside of CFPB s supervisory and enforcement powers. CFPB s Indirect Auto Financing Guidance (March 2013) Dealer markups of lender s buy interest rate Disparate Impact credit discriminatory auto loans concern Disparate Treatment v. Disparate Impact No facial discrimination, e.g., minimum income credit standard Credit practice results in disproportionate adverse impact on protected class of individuals No discriminatory intent proof requirement If disparate impact shown, then burden is on lender to show legitimate business practice and no less disparate means available

25 CFPB and Auto Dealer Finance Space Township of Mount Holly v. Mt. Holly Gardens Citizens in Action, key dispute impact case under federal Fair Housing Act settled in November 2013 just before Supreme Court oral arguments, which could have impacted CFPB s disparate impact discrimination enforcement position and actions American Insurance Association and National Association of Mutual Insurance Companies v. Department of Housing and Urban Development, pending suit challenging HUD s Dispute Impact Discrimination Regulation promulgated in February 2013 as applied to homeowner s insurance, which is a significant issue for homeowner s insurance companies and could impact CFPB s disparate impact discrimination enforcement position and actions

26 CFPB s Indirect Auto Financing Guidance Lenders should have comprehensive fair lending compliance programs for auto dealer rate participation contracts Lenders should monitor disparate impact of auto dealer originated loans on dealer-by-dealer basis and at lender s auto loans portfolio level Instead (hint, hint), lenders can just pay fixed fees to auto dealers for auto loan origination CFPB currently investigating 4-5 national lenders for credit discrimination related to auto loan rate mark-ups and has recently extracted its first consent order for settlement of this issue against one major auto finance lender

27 CFPB Regulations Involving Insurance Products Lender Forced-Placed Home Insurance - Mortgage Loan Servicers RESPA Regulation X amended in 2013 to enhance transparency of forced-placed insurance and new borrower protection rules Could migrate to lender-placed auto insurance Financing of Credit Insurance Loan Originators Compensation Requirements under Truth in Lending Act (Reg. Z) adopted in 2013 and prohibits mortgage lenders from financing single premium credit insurance (life, disability, health, unemployment and property) in connection with consumer credit transaction secured by a dwelling Excludes monthly premium payment credit insurance Excludes credit unemployment insurance if premiums reasonable and insurer is not affiliate of lender What about insurance premium finance loans?

28 Major CFPB Consent Orders with Banks and Credit Card Companies Company Consent Order Date Fine Restitution Bank of America April 2014 $20mm Est. $727mm AMEX December 2013 $2mm $18.6mm Ally Financial December 2013 $18mm $80mm Cash America November 2013 $5mm $8mm JP Morgan/Chase September 2013 $20mm Est. $309mm AMEX October 2012 $14.1mm $85mm Discover Bank September 2012 $7mm $200mm

29 CFPB Consent Orders with Forced Placed Insurance Companies Alleged illegal kick-backs by forced-placed insurers to mortgage lenders through their captive reinsurers Company Consent Order Date Fine Restitution Republic Mortgage November 2013 $100k None Radian Guaranty April 2013 $3.75mm None United Guaranty April 2013 $4.5mm None Genworth Mortgage April 2013 $4.5mm None MGIC A il2013 $2 65 N

30 CFPB Consent Order for Vehicle Service Contracts and GAP Waivers Dealers Financial Services Dealer Financial Services/US Bank MILES auto loan program for military service persons CFPB s allegations: TILA violation for requiring use of military payment allotments as loan repayment source Deceptive brochure statement that VSC adds just a few dollars to your monthly payment Deceptive brochure statement by saying you pay zero for claims without prominently disclosing parts excluded from VSC s coverage Deceptive sales agents statements that GAP waiver would add just a few cents to your car payment

31 QUESTIONS? ANSWERS! Brian T. Casey, Esq. Locke Lord LLP Terminus Piedmont Rd., NE, Suite 1200 Atlanta, GA Direct: Fax: DISCLAIMER: Mr. Casey and Locke Lord LLP ( LL ) disclaim all liability whatsoever in relation to any materials or information provided at this event. In addition, any written materials or other information provided by Mr. Casey or LL, and any presentations made generally to the participants at this event, are solely for informational purposes; they do not, nor are they intended to, constitute legal advice or create an attorney-client relationship.

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