In October 2015, a CFPB consent order found that SNAAC had indeed engaged in unfair, deceptive, and abusive acts and practices while collecting on these auto loans.
The CFPB is issuing todays consent order against SNAAC for violating the terms of the 2015 consent order by failing to properly give refunds or credits to affected borrowers.
Issuing worthless credits to settled-in-full accounts: In purporting to provide redress, SNAAC treated accounts that were settled-in-full as having a positive account balance.
Issuing worthless credits to discharged accounts: SNAAC also issued worthless account credits to consumers whose debts had been discharged in bankruptcy, and who no longer owed SNAAC money on their auto loan.
Failing to properly give redress to consumers making payments under settlement agreements: Some SNAAC consumers were making payments under settlement agreements.