Penalty Amount
$694,000,000
New Jersey's Attorney General and Division of Consumer Affairs, along with 41 Attorneys General, reached a $694 million settlement with subprime auto lender Credit Acceptance Corporation over allegations it originated unaffordable loans its own systems predicted borrowers could not repay, employed aggressive debt-collection tactics, and failed to prevent deceptive vehicle-service contract and GAP product 'packing' by dealers. The multistate settlement stepped in after the CFPB permanently dropped its 2023 enforcement action against CAC in 2025. CAC will provide $60 million in cash restitution, $634 million in debt relief, an additional $15 million to the states, and implement injunctive lending reforms including loan off ramps, pre-loan disclosures, add-on packing safeguards, and a seven-year vehicle price cap. Note: this is a consumer-protection lending enforcement action, not a privacy matter; violation categories are best-fit mappings from the available taxonomy.
CAC will provide $694 million total in cash and debt relief: $60 million in nationwide cash restitution distributed by the Attorneys General to consumers with particularly risky loans; $388 million in debt relief for consumers whose cars were repossessed; and $246 million in debt relief allowing consumers whose cars were not repossessed to keep their cars (covering certain risky loans made November 1, 2015 through November 30, 2025), plus an additional $15 million paid to the Attorneys General. New Jersey receives more than $28.5 million, including approximately $2.2 million in restitution and $25.6 million in debt relief. Injunctive terms, memorialized in a Final Consent Judgment, require: five-year loan 'off ramps' starting November 2, 2026 providing qualifying consumers 95% debt relief and barring collections lawsuits; a process to prevent unlawful VSC/GAP packing including pre-purchase disclosures, post-purchase alerts, easier cancellation, and dealer monitoring; pre-loan disclosures about default risk and vehicle value; a seven-year price cap of 109% of retail book value for certain consumers; and processes preventing dealers from raising prices based on creditworthiness or above advertised prices.
Although this is a consumer-protection lending enforcement rather than a privacy action, in-house counsel at auto finance companies, lenders, and dealerships should review dealer agreements and third-party contracts for provisions governing add-on product sales and loan origination. Specifically: (1) dealer agreements - audit compensation methodologies and dealer oversight/monitoring clauses that could incentivize VSC/GAP 'packing,' and require contractual dealer compliance with pre-purchase disclosures, post-purchase purchase confirmations, and easy-cancellation processes; (2) VSC and GAP product provider contracts - align with the settlement-mandated packing-prevention process and consumer cancellation rights; (3) loan origination policies, underwriting criteria, and any vendor tools relying on internal loan 'scores' - verify ability-to-repay standards, the 109%-of-retail-book-value price cap, and prohibitions on raising prices based on creditworthiness or above advertised prices; (4) debt collection vendor agreements and litigation referral guidelines - accommodate the five-year off-ramp obligation barring collections lawsuits against qualifying borrowers; and (5) consumer-facing financing contracts - update disclosures regarding default risks, vehicle value, and add-on purchases. Organizations party to the consent judgment should map each injunctive term to responsible business units and refresh compliance program, monitoring, and reporting clauses in vendor contracts accordingly.
Entity
Credit Acceptance Corporation (CAC)
Industry
Financial ServicesOfficial Press Release
https://www.njoag.gov/new-jersey-announces-694-million-settlement-with-subprime-auto-lender-credit-acceptance-corporation-for-making-unaffordable-designed-to-fail-loans/
2026 0917 Final Consent Judgment CAC
http://www.njoag.gov/wp-content/uploads/2026/09/2026-0917_Final-Consent-Judgment_CAC.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"Credit Acceptance Corporation (CAC)"
"one of the nation’s largest auto finance companies"
"For Immediate Release: September 17, 2026"
"will provide $694 million in cash and debt relief to car buyers who received a CAC auto loan"
"The settlement provides $60 million in nationwide cash restitution"
"CAC also will provide $388 million in debt relief to consumers whose cars were repossessed, and $246 million in debt relief to consumers whose cars were not repossessed"
$650K
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$400.0M
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