The CFPB’s reach equals its grasp - Using indirect lenders to regulate the auto dealership industry. What it may not do directly, the CFPB may find a way to do INdirectly. If your credit union provides certain rate-spread or retainage benefits for dealers to send you “C” and “D” paper, beware that dealers may be misusing those opportunities in ways that may (inadvertently) discriminate against certain classes of borrowers. The appearance of impropriety is at least as important as its actual presence, since both invite equal credit opportunity scrutiny by the CFPB. Learn the earmarks of such practices, how to avoid them and how to avoid seeing your credit union atone for the sins actually committed by your assigning dealer.