The Consumer Financial Protection Bureau on September 17 issued a proposal to supervise nonbank companies that qualify as "larger participants" in the automobile financing and leasing market. As proposed, this will cover any company that originates at least 10,000 auto finance and leasing contracts per year. Nonbank larger participants would include specialty finance companies, "captive" finance companies and "Buy Here Pay Here" (BHPH) finance companies.

In this webinar, we will examine the scope of the proposed rule and explain how, once adopted, it will change the game for nonbank auto finance companies. We will conclude with some concrete recommendations for nonbank auto finance companies on preparing for supervisory examinations by the Bureau.


  • Authority and scope of the proposed larger participant rule for the auto finance market 
  • The consequences for larger nonbank participants and their service providers
  • The consequences for nonbanks that are not larger participants and their service providers
  • A discussion of how to prepare for supervisory examinations by the CFPB
  • The "hot button" issues the CFPB is focusing on in its examinations of the auto finance operations of large banks and in its pending investigations of nonbank auto finance, "buy here, pay here" dealers and auto title lenders, as well as other "hot button" issues discussed in the notice of proposed rulemaking


12:00 PM - 1:00 PM ET | Webinar


Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group


Peter N. Cubita
Consumer Financial Services Group

John L. Culhane, Jr.
Consumer Financial Services Group

Christopher J. Willis
Consumer Financial Services Group

This program is open to Ballard Spahr clients and members of the financial services industry. There is no cost to attend. This program is not eligible for continuing education credits.

Please register at least two days before the webinar. Login details will be sent to all approved registrants. For more information, contact Lisa Prickril at

Related Practice

Consumer Financial Services