My question relates to the alternative notice permitted to be given under 12 CFR 1022.74(f). For indirect auto loans, lenders are permitted to have the auto dealer provide the notice to the consumer. The auto dealers' forms typically include the FRB's or FTC's website address.
In light of the upcoming requirement effective January 1, 2013, regarding the change to the CFPB's name and address, am I correct that auto dealers will need to make this change on these notices since they are providing them on behalf of the lender? If so, should they eliminate the references to both the FRB and the FTC and replace that with CFPB? Since the dealer is not regulated by CFPB, should they just replace the FRB name and address with CFPB, but include FTC along with CFPB?