John Redding Quoted in Auto Finance News Article, "Small Businesses Protest CFPB's 'Larger Participant' RuleJohn C. Redding
John Redding was quoted in Larissa Padden's Auto Finance News article, titled "Small Businesses Protest Protest CFPB's 'Larger Participant' Definition," on December 9, 2014.
Attorney John Redding, Partner at Buckley Sandler LLP, drafted a letter to the CFPB, arguing that the financial impact and burden on companies caught under the net of the proposed rule would be greater for smaller businesses with fewer resources.
“On their behalf, we have filed a comment suggesting that it’s inappropriate to include small businesses, as defined by the Small Business Administration,” Redding told Auto Finance News. “And who have a very small percentage of the market, and then subject them to supervision, given the impact on their business.”
In the letter, Redding represents a group of small businesses proposing the threshold for contracts that define companies as a larger participant be increased significantly. The current threshold proposed by the CFPB is companies that make, acquire, or refinance at least 10,000 or more loans or leases in a year.
“The Clients suggest that the Proposed Rule’s threshold be increased significantly from 10,000 aggregate annual originations,” Redding wrote. “For example, and as highlighted by the Bureau, adoption of a 50,000 aggregate annual originations threshold would still provide for supervision of the “17 very largest participants in the market, representing approximately 86% of market activity.”