Submission Number: 00077
Received: 2/22/2012 6:46:34 PM
State: Rhode Island
Agency: Federal Trade Commission
Initiative: Public Roundtables: Protecting Consumers in the Sale and Leasing of Motor Vehicles; Project No. P104811
Attachments: No Attachments
It is an unfair and discriminating lending practice for a Bank/Lender to offer a dealer a "buy rate" and for the dealer to be allowed to upcharge that rate to the borrower(s) for an additional 1 - 3 points, depending on the program granted by the Bank/Lender to the dealer. 1. If this practice continues, the borrower should be given a disclosure, requiring the borrower(s) signatures, indicating the buy rate offered by the Bank/Lender to the Dealer and rate of interest the charged to the borrower(s). This undisclosed "buy rate" vs. contract rate would never fly in the Mortgage field without being disclosed to the borrower(s. Why is it allowed in Auto Lending? 2. It can also be labeled as a discriminatory practice as not all borrower(s) are charged the same amount of rate difference between “buy rate” and contract rate. 3.The goverment chose to dis-allow this practice in the Mortgage industry but has not yet addressed the same issue in the consumer/auto industry.