Snap Finance LLC, Snap RTO LLC, Snap Second Look LLC, Snap U.S. Holdings LLC, Snap Finance Holdings LLC
On July 19, 2023, the Bureau filed a lawsuit against Snap Finance LLC, Snap RTO LLC, Snap Second Look LLC, Snap U.S. Holdings LLC, and Snap Finance Holdings LLC (collectively, Snap), a group of interrelated companies headquartered in West Valley, Utah. Snap offers and provides so-called “lease-purchase” or “rental-purchase” financing, through which consumers finance merchandise and services from merchants and, in turn, make payments back to Snap. Since January 2017, Snap has offered and provided more than three million financing agreements to consumers in partnership with over 10,000 merchants in 47 states. The Bureau alleges that, during this period, Snap designed and implemented its financing program in ways that misled these consumers through the advertising, servicing, and collections of its agreements, failed to provide consumers with required disclosures, and interfered with consumers’ ability to understand the terms and conditions of their agreements. The Bureau alleges that such conduct violated the Consumer Financial Protection Act of 2010’s prohibition of deceptive and abusive acts and practices and the Truth in Lending Act and its implementing Regulation Z. The Bureau further alleges that Snap violated the Electronic Fund Transfer Act and its implementing Regulation E by unlawfully conditioning the extension of credit on consumers’ repayment through preauthorized ACH debits, and the Fair Credit Reporting Act and its implementing Regulation V by failing to establish and implement reasonable written policies and procedures concerning the accuracy and integrity of consumer information that it furnished. The Bureau seeks, among other things, injunctions to prevent future violations, rescission or reformation of Snap’s financing agreements, redress to consumers, and civil money penalties.