07
Dec
By Richard P. Eckman | Mark T. Dabertin | Scott D. Samlin | Avinoam D. Erdfarb | Pepper Hamilton LLP
This client alert has been updated from its original form to address the GAO opinion issued on Dec. 5, 2017.
On December 5, the Government Accountability Office (GAO) essentially invalidated the CFPB’s auto lending guidance by finding that it constitutes a “rule” for purposes of the Congressional Review Act (CRA). As a rule, the guidance was required to be submitted to...