John Redding Quoted in Auto Finance News Article, "CFPB Finalizes 'Larger Participant' Rule With Only 'Minor Changes'"John C. Redding
John Redding was quoted in Larissa Padden's Auto Finance News article, "CFPB Finalizes 'Larger Participant' Rule With Only 'Minor Changes,'" on June 10, 2015.
The proposed rule, which was announced in September 2014, was subject to a 60 day open comment period after it was published in the Federal Register on October 8, 2014. In the comment period, small businesses voiced their displeasure at being included under the rule.
In one letter representing a group of small businesses, Attorney John Redding, Partner at Buckley Sandler LLP proposed that the threshold for contracts which define companies as a larger participant be increased significantly. Separately, the American Financial Services Association, a lender group, also suggested a higher threshold.
“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.”