• On May 7, 2019, we received a subpoena from the Consumer Frauds and Protection Bureau of the Office of the New
York State Attorney General, relating to the Company’s origination and collection policies and procedures in the state
of New York. On July 30, 2020, we received two additional subpoenas from the Office of the New York State
Attorney General, both from the Consumer Frauds and Protection Bureau and the Investor Protection Bureau, relating
to the Company’s origination and collection policies and procedures in the state of New York and its securitizations.
On August 28, 2020, we were informed that one of the two additional subpoenas was being withdrawn. On November
16, 2020, we received an additional subpoena for documents from the Office of the New York State Attorney General.
On November 19, 2020, the Company received a letter from the Office of the New York State Attorney General
stating that the New York State Attorney General is considering bringing claims against the Company under the Dodd-
Frank Act, New York Executive Law § 63(12), the New York Martin Act and New York General Business Law § 349
in connection with the Company’s origination and securitization practices. On December 9, 2020, we responded to the
New York State Attorney General’s letter, disputing the assertions contained therein. On December 21, 2020, we
received two additional subpoenas from the Office of the New York State Attorney General, one relating to data and
the other seeking testimony. On February 24 and April 30, 2021, we received additional subpoenas from the Office of
the New York State Attorney General seeking information relating to its investigation.
• On April 22, 2019, we received a civil investigative demand from the Bureau seeking, among other things, certain
information relating to the Company’s origination and collection of Consumer Loans, TPPs and credit reporting. On
May 7, 2020, we received another civil investigative demand from the Bureau seeking additional information relating
to its investigation. The Company raised various objections to the May 7, 2020 civil investigative demand, and on May
26, 2020, we were notified that it was withdrawn. On June 1, 2020, we received another civil investigative demand
that was similar to the May 7, 2020 demand, and which raised many of the same objections. We formally petitioned
the Bureau to modify the June 1, 2020 civil investigative demand. On September 3, 2020, the Director of the Bureau
denied our petition to modify the June 1, 2020 civil investigative demand. On December 23, 2020, we received a civil
investigative demand for investigational hearings in connection with the Bureau’s investigation. The Company
objected to certain portions of the civil investigative demands for hearings and, on January 19, 2021, the Bureau
notified the Company that it had withdrawn such portions from the December 23, 2020 civil investigative demands.
On March 11, 2021, we received another civil investigative demand from the Bureau seeking additional information
relating to its investigation and an investigational hearing. On June 3, 2021, we received another civil investigative
demand from the Bureau seeking additional information relating to its investigation. On December 6, 2021, we
received a Notice and Opportunity to Respond and Advise (“NORA”) letter from the Staff of the Office of
Enforcement (“Staff”) of the Bureau, stating that Staff is considering whether to recommend that the Bureau take legal
action against the Company for alleged violations of the Consumer Financial Protection Act (the “CFPA”) in
connection with the Company’s consumer loan origination practices. The NORA letter states that the Bureau may
allege that the Company (i) committed abusive and unfair acts or practices in violation of 12 U.S.C. § 5531(c) and (d)
and 12 U.S.C. § 5536(a)(1)(B) and (ii) substantially assisted the deceptive acts of others in violation of 12 U.S.C. §
5536 (a)(3). The NORA letter also states that, in connection with any action, the Bureau may seek all remedies
available under the CFPA, including civil money penalties, consumer redress and injunctive relief. On January 18,
2022, the Company responded to the NORA letter disputing that it had committed any violations.
• On March 18, 2016, we received a subpoena from the Attorney General of the State of Maryland, relating to the
Company’s repossession and sale policies and procedures in the state of Maryland. On April 3, 2020, we received a
subpoena from the Attorney General of the State of Maryland relating to the Company’s origination and collection
policies and procedures in the state of Maryland. On August 11, 2020, we received a subpoena from the Attorney
General of the State of Maryland restating most of the requests contained in the March 18, 2016 and April 3, 2020
subpoenas, making additional requests, and expanding the inquiry to include 40 other states (Alabama, Alaska,
Arizona, Arkansas, California, Connecticut, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Iowa, Kansas,
Kentucky, Louisiana, Maine, Michigan, Minnesota, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico,
North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota,
Tennessee, Texas, Utah, Vermont, Virginia, Washington, and Wisconsin) and the District of Columbia. Also on
August 11, 2020, we received from the Attorney General of the State of New Jersey a subpoena that is essentially
identical to the August 11, 2020 Maryland subpoena, both as to substance and as to the jurisdictions identified.
• On December 9, 2014, we received a civil investigative subpoena from the U.S. Department of Justice pursuant to the
Financial Institutions Reform, Recovery, and Enforcement Act of 1989 directing us to produce certain information
relating to subprime automotive finance and related securitization activities.
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