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Rebuilding Trust Through Independent FTC Oversight

Following allegations of violations of multiple consumer protections laws, a prominent automotive loan servicer entered into a Settlement Order with the FTC. FTI Consulting was approved as the independent third-party monitor to evaluate the company’s compliance and strengthen its consumer data integrity program.

Our Impact

FTI Consulting validated $3.6 million in regulator-approved customer remediation, in addition to a $2 million fine, and confirmed the corrected overcharges and the client’s compliance with regulatory requirements.
Over the course of the 10-year monitorship, the company avoided further penalties and successfully mitigated the potential for overcharged fees, interest and other forms of consumer harm, such as inaccurate reporting to credit reporting agencies.
FTI Consulting’s work and recommendations were accepted by both the FTC and the company, helping reduce regulatory uncertainty, validating the company’s compliance progress, reinforcing consumer protections and rebuilding consumer and regulatory trust and confidence.

Our Role

FTI Consulting conducted extensive biennial reviews of the company’s end-to-end operations to support the development of the consumer data integrity program, communicate the program’s effectiveness to the FTC and certify the program’s ongoing compliance with the terms and protections required by the Settlement Order.
Our experts conducted in-depth interviews with responsible corporate officers and employees, reviewed responses to all identified issues and complaints and performed statistically valid testing of loan servicing records to ensure interest, fees and payment applications complied with state-by-state requirements.
At the request of the FTC, our work also included investigating ongoing complaints submitted to the FTC, Consumer Financial Protection Bureau and other federal and state agencies, including analyzing trends related to alleged improper interest calculations, late fees, credit reporting issues and servicing practices to identify potential systemic failures.
We delivered four initial procedures and findings reports and five subsequent biennial reports to the FTC — providing independent, comprehensive assessments of the company’s compliance with all terms of the Order, which included identifying key risk areas across the company’s data integrity program along with recommended enhancements to reduce such risks and improve operational controls.