With interest rates and car values rising, the cost of ownership has become a significant burden for customers and a focal point for regulators. Delinquencies have seen a notable surge, particularly among low-income consumers with subprime credit.
Recently, the Federal Trade Commission ("FTC") has leveraged the Federal Equal Credit Opportunity Act (1974) aggressively to address the rising costs of vehicle ownership. The FTC has pursued over 50 cases fair lending cases against dealerships, and collaborated with state regulatory agencies for national sweeps resulting in 181 actions. Even with more aggressive regulation, more than 100,000 complaints have been filed against dealerships in the last three years.
