Automotive Finance: Will dealership finance reserve go the way of mortgage yield spread premiums?

A recent Consumer Financial Protection Bureau (CFPB) bulletin makes it clear that certain lenders that offer auto loans through dealerships are liable under the Equal Credit Opportunity Act (ECOA). In this paper, the authors frame the cost of auto financing in the context of the overall vehicle purchase transaction, whereby multiple products and services are bundled and simultaneously priced. They also draw distinctions between the roles of the auto dealership and the mortgage broker in their respective markets, since the role of mortgage brokers has figured prominently in fair lending enforcement actions by federal regulators over the last 24 months.