On January 6, the CFPB filed a complaint against a non-bank manufactured home financing company, alleging the company failed to make “reasonable and good-faith determination[s] that their borrowers would have a reasonable ability to repay” the loans they obtained to purchase manufactured homes, as required by the TILA and its implementing Regulation Z. The complaint asserts that the company ignored “clear and obvious red flags” that certain consumers would be unable to meet their loan obligations, such as by using implausibly low estimates for borrowers’ monthly living expenses and disregarding existing debts in collections. These alleged practices led to the origination of loans that borrowers could not afford, resulting in late fees, penalties, and, in many cases, home repossessions.  The CFPB seeks various forms of relief, including a permanent injunction to prevent future violations, monetary damages, restitution for affected consumers, and civil money penalties.