CFPB Sues Five Title Lenders for Failing to Disclose APR

The CFPB brought suit against five title lenders.  The CFPB is alleging the lender companies failed to disclose their annual percentage rate in their online advertisements.  Under the Truth in Lending Act the annual percentage rate (APR) must be disclosed in almost all consumer credit transactions.[1]  The CFPB claims one company went so far as to advise the consumer to take their interest rate and multiply it by twelve, but failed to disclose that was the annual percentage rate.


[1] Consumer Financial Protection Bureau, CFPB Rules and Regulation TILA, Truth in Lending Act (2015) at 14, available at:  http://files.consumerfinance.gov/f/201503_cfpb_truth-in-lending-act.pdf

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Dean Brown is a seasoned business professional with 20 years of audit experience. Dean specializes in System and Organization Controls (SOC) audits, which he has been conducting as the principal auditor since 2014. Dean has also conducted numerous controls, IT, operations, compliance and forensic audits over the duration of his career. His experience involves financial, IT, SOC (SOC 1, SOC 2, SOC 3 and SOC for Cybersecurity), operations and compliance audits, examinations, review and consulting engagements. Dean is a subject matter expert in SSAE18/SOC 1, SOC 2 audits, ISO 27001, enterprise risk management, internal controls, information security management systems, and IT governance models. Dean began his career as an auditor at a Big 4 public accounting firm where he audited multiple fortune 500 companies. Later in his role as a lead auditor at a fortune 500 company he managed teams in the United States and Canada and was instrumental in the management and successful completion of a company-wide project that successfully transition the company to a new operating business model. Dean is responsible for crafting, communicating, and reinforcing CompVisory’s vision and mission, and empowering the CompVisory team with the guidance and resources necessary for their achievement.