SFA Responds to FTC Proposal on Auto Dealer Practices with Trust/Investor Liability Implications

This Monday, September 12, SFA submitted a comment letter to the Federal Trade Commission (FTC) in response to their proposal related to the sale, financing, and leasing of motor vehicles by dealers. The proposal aims to address unfair and deceptive auto dealer practices but also posed unintended consequences for our market by exposing securitization investors to liability as a result of compliance failures that they cannot meaningfully control, nor contractually agreed to bear. In our response, SFA educated the FTC on the impropriety of pushing liability down to the Trusts and investors and recommended that clarifying language be introduced into the proposal to avoid these unintended consequences.

Read More.