Repo Alliance – Washington Moves Stir New Concerns for Repo Industry

Washington DC – April 16, 2026 – A new legislative move in Washington is drawing attention across the repossession industry, and the Repo Alliance is stepping forward to break down what it really means on the ground. As federal oversight shifts and long-standing consumer protection guidance faces uncertainty, industry leaders warn that the ripple effects could reshape risk, accountability, and the future of recovery operations nationwide.

Congress reconvened Monday after a two-week recess for Easter. The first action Senator Elizabeth Warren (D-Massachusetts) took upon returning was to introduce a joint resolution related to repossessions.

Officially the title of the legislation is: “A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Consumer Financial Protection relating to the withdrawal of the rule relating to ‘Bulletin 2022-04: Mitigating Harm from Repossession of Automobiles’.” A resolution of disapproval is a legislative measure Congress takes to block an executive branch action.

As you remember, in 2022 (under the Biden Administration), CFPB issued a bulletin determining certain practices regarding repossessions to be unfair, deceptive, abusive acts or practices (UDAAPs). It dealt with wrongful repossessions, personal property fees, and collateral protection insurance. The bulletin encouraged lenders to undertake 13 measures to mitigate the risk of wrongful repossessions. Then, in May of 2025 (under the second Trump Administration), CFPB withdrew the 2022 bulletin.

Senator Warren’s legislation effectively says, “Congress officially blocks CFPB from withdrawing the 2022 bulletin.” Of course, both chambers of Congress would have to approve Warren’s resolution, and then President Trump would have to sign it into law. Those steps are highly unlikely, at least for this year.

So, what does this mean to the repossession community?

Under the Dodd-Frank Act, all covered persons or service providers are prohibited from committing unfair, deceptive, or abusive acts or practices in violation of the Act. An act or practice is unfair when (i) it causes or is likely to cause substantial injury to consumers; (ii) the injury is not reasonably avoidable by consumers; and (iii) the injury is not outweighed by countervailing benefits to consumers or to competition.

The Dodd-Frank Act prohibits two types of abusive practices. First, materially

interfering with the ability of a consumer to understand a term or condition of a product or service is abusive. Second, taking unreasonable advantage of statutorily specified market imbalances is abusive.

Those market imbalances include

(1) a consumer’s lack of understanding of the material risks, costs or conditions of a product or service,

(2) a consumer’s inability to protect their interests in selecting or using a product or service, or

(3) a consumer’s reasonable reliance on a covered person to act in their interests.

I want to be sure everyone understands this is not political—this is just trying to bring street level understanding to this action.

The CFPB listed items they found lenders doing they believed to be abusive acts. Many of these items are the very situations that cause our businesses and agents to suffer reputational harm and nuisance lawsuits.

Bureau found that an entity engaged in an unfair act or practice when it wrongfully repossessed consumers’ vehicles.
The servicer told consumers it would not repossess vehicles when they were less than 60 days past due. Additionally, the servicer maintained a policy and told consumers that it would not repossess vehicles of consumers who had entered into an agreement to extend the loan, or who had made a promise to make a payment on a specific date and that date had not passed or who successfully kept a promise to pay. Nevertheless, the servicer wrongfully repossessed vehicles from hundreds of consumers who had:

Made and kept promises to pay that brought the account current
Made payments that decreased delinquency to less than 60 days past due.
Made promises to pay where the date had not passed; or
Agreed to extension agreements.

In addition, lenders are warned about:

Servicers incorrectly coded consumers as delinquent.
Servicer representatives failed to cancel repossession orders that had previously been communicated to repossession agents; or
Repossession agents failed to confirm that the repossession order was still active prior to repossessing a vehicle.
They did not adhere to Bankruptcy guidelines in particular automatic stays.
And many other points.

The main point:

During the current administration, the CFPB withdrew its guidance bulletins and enforcement virtually removing responsibility and accountability and enforcement in abusive tactics, as well as many other areas.

Today, the movement to dismantle the CFPB, or at least greatly minimize its effect, opens the door to our industry being the victim of inadequate protection because of the wording in our indemnification clauses and other contractual language. Although it is getting better, the number one reason for wrongful repossession claims is still lender error.

The repossession industry, like any industry, has a reasonable skepticism of legislation which empowers regulators. Many times, our industry needs a regulator big enough to exert oversight over the lending industry that has extensive power over commerce and often frustrates our industry.

Regardless whether Senator Warren succeeds in reasserting CFPB control over repossessions or not, the legislation is a major announcement. We will keep a diligent watch on the proceedings on Capitol Hill and move immediately if movement appears.

WHO IS REPO ALLIANCE?

How and when was the group formed?

The initiative started several weeks ago with an invitation from ARA to all National and State Associations and other major industry leaders.

Is the Repo Alliance another association?

NO! The Repo Alliance is a collaborative effort of the groups which decided to answer the call and develop a fundraising program to further the interests of OUR industry and provide a voice at both National and State levels.

Which organizations came together?

American Recovery Association (ARA), the California Association of Licensed Repossessors (CALR), Texas Accredited Repossession Professionals (Texas ARP), and Harding Brooks Insurance.

How do you contribute?

A Square account has been established.
Click here to donate through Square.
Champion, Promote and Spread the word about this industry initiative!

Can I use any other method to contribute?

YES, you can mail a check, payable to Repo Alliance at 1400 Corporate Dr., Suite 175, Irving, TX, 75038.

Will funding reports and expenditures be available for review?

YES, this initiative will be completely transparent on monies raised with information available on the website.
One hundred percent of all monies raised will be used to pay for lobbying efforts. Everyone involved other than the lobbyist is a volunteer.

Why hire a dedicated lobbyist instead of just working with other lobbying groups?

We are working with other industry lobbyist groups but have realized without OUR OWN VOICE, we would be trusting the future of the Recovery Industry to the priorities of others. Riding the coattails of these other groups, puts our agenda as simply an afterthought.

What are the GOALS?

Change the negative, reputational image of the Recovery Industry.
Educate legislatures of the vital role we play.
Fight against language in bills or guidance from agencies that would decimate the recovery industry.

Contact Us

[email protected]

Repoalliance.com

833-737-6255

833-REPOALL

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