The CFPB has subpoenaed a number of auto lenders concerning the sale of financial products such as extended warranties, according to a report in the May 2, 2013 edition of the Wall Street Journal.  Consumer advocates have long criticized what they perceive to be excessive use of high-cost ancillary products to boost profits for car dealers.  Although there is nothing illegal about any of these products, and many provide significant benefits to consumers, we nonetheless expect the CFPB to use its UDAAP powers to deem certain of these practices “abusive,” and to use fair lending-based methodologies to argue that these sales have a disparate impact on certain protected classes.  When combined with the CFPB’s March 2013 guidance on indirect auto lending, which we discuss here, the CFPB is demonstrating that auto lending will be an area of significant enforcement activities in the months to come.