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24      TIME TO LIVE
                  YOUR DREAMS






          Arbitration Clauses: CFPB is   Disparate Impact: Simply put,
        also taking a look at mortgage   this is unintentional discrimination
        arbitration clauses. If the use   that happens when only certain
        of “forced arbitration” through   customers can borrow and the
        these clauses is banned in credit   auto lenders will be facing these
        agreements, it raises the cost   issues. If lending platforms engage
        of doing business because the   in this as well through thier
        potential litigation costs are   underwriting algorithm, however
        immediately increased. Does this   well intended and complete, they
        then send a tremor through the   could be in hot water.
        rest of the credit industry for non   Regulations are here to stay
        mortgage lenders using a “forced   and ever increasing. Compliance
        arbitration” clause?        will become a more important
          Enforcement Activity: What’s   part of everyone’s business. You
        likely on the agenda: Mortgage   can bank on that. Businesses
        Servicing, Telecommunications   will have to evolve and adapt to
        companies charging 3rd party fees   this new and more complicated
        for products unauthorized by the   environment. But, perhaps this is a
        consumer and more global and   good thing. If everyone operates at
        granular disclosure in consumer   a better practices standard, don’t
        complaint narratives.       we all win?









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