Legal Seminar

Vehicle Repossessions • Auction values held in the near term, so did not impact customers whose vehicles were previously repossessed initially • Repossessions effectively ended during initial phase of COVID – The vast majority of the industry voluntarily suspended repossessions – it simply didn’t make sense – A number of states also prohibited repossessions, and some are considering further prohibitions • Unlimited prohibitions have negative consequences for everyone – Industry remains focused on avoiding repossessions when they can

Issues in Unsecured Consumer Lending • Concerns over new loans

– Consumers continue to seek unsecured credit through multiple channels at the same time – Use of funds to pay past creditors may result in “musical chairs” approach to consumer credit, increasing risk and cost of credit – Underwriting of loans significantly more challenging given limitations on credit reporting and potential risks on use of information • Impact on servicing-related activities – Industry has largely implemented voluntary extensions / deferrals without requiring proof of need or charging fees

– Concern over mandated requirements without evidence of future ability to pay – What is the impact of mandated, unilateral extensions on statute of limitations