Consumer complaint received 2025-05-09 00:00:00
Product: Vehicle loan or lease — Loan
Issue: Repossession — Notice to repossess
Company: Lentegrity Management, LLC
State: VA

Complaint narrative:
RE : Complaint for violation of the Final Rule on Arbitration passed on XX/XX/XXXX HERE COMES NOW, XXXX XXXX, the plaintiff in this case, humbly and respectfully filing a complaint against defendants Lentegrity LLC and XXXX XXXX XXXX XXXX XXXX XXXX for the violation of the Final Rule on Arbitration ( the Final Rule or the Rule ) that was passed on XX/XX/XXXX which prohibits the use of pre-dispute arbitration provisions in consumer financial products and services. 
The Rule was published in the XXXX XXXX on XX/XX/XXXX, and became effective on XX/XX/XXXX ( the Effective Date ) with mandatory compliance required beginning XX/XX/XXXX ( the Compliance Date ). 
The plaintiff is currently in litigation against the defendants where the case is pending at the XXXX XXXX XXXX XXXX XXXX for the XXXX XXXX under case number XXXX and initially filed at the XXXX XXXX XXXXXXXX XXXX XXXX XXXX Virginia XXXX XXXX XXXX XXXX number XXXX. 
The plaintiff alleges that he experienced predatory lending when he purchased a vehicle from the defendant XXXX XXXX XXXX at XXXX XXXX XXXX XXXX XXXX, VA XXXX on the date of XX/XX/XXXX. The vehicle was priced at XXXX XXXX but the plaintiff borrowed an auto loan which was disbursed by Lentegrity LLC as per the plaintiffs credit report, even though the sales contract shows that XXXX XXXX XXXX is the lender. 
The vehicle was priced at XXXX , but plaintiff did not have the cash amount, therefore he borrowed an auto loan. The predatory practice that the defendants engaged in is adding hidden fees which increased the value of the vehicle to XXXX $ which became the loan amount. 
The vehicle was priced at about XXXX , but it was overpriced to XXXX $ which is a difference of XXXX $ ( XXXX - XXXX = XXXX $ ). The XXXX $ amount became the loan amount borrowed by the plaintiff where XXXX $ was meant for the vehicle and the XXXX $ became the fee for disbursing the loan from the defendant XXXX XXXX XXXX. The plaintiff is supposed to pay again XXXX $ as the finance fee for borrowing XXXX $ from the same auto dealer selling the vehicle. 
The auto loan agreement between the plaintiff and XXXX XXXX XXXX are : a. The loan amount is XXXX XXXX 
b. The Annual Percentage Rate ( XXXXnterest Rate ) is 15.99 %. 
c. The loan term is 60 months or 5 years. 
d. The monthly payment is XXXX XXXX 
e. The total amount to be paid at the end of the loan is XXXX XXXX 
f. The Finance charge is XXXX XXXX 

The defendants consumer credit businesses were formed in XX/XX/XXXX for Lentegrity LLC and XXXX XXXX XXXX XXXX XXXX XXXX was formed XX/XX/XXXX, yet the compliance date for the final rule on arbitration started on XX/XX/XXXX, therefore when the defendants sold the plaintiff the vehicle on XX/XX/XXXX, they were already required to be in compliance and as such, they failed to edit their sales contract to remove the pre dispute arbitration clause and now when the plaintiff had a dispute against them, they forced the plaintiff into arbitration which is clearly against the Final Rule on Arbitration. 



The plaintiff discovered the information and informed them about it and requested them to cancel any pending arbitration hearing with XXXX XXXX, but they are adamant and refusing to cancel the arbitration hearing and now we must take it that they are willfully neglecting to be in compliance with the Final Rule on Arbitration which is within your jurisdiction to take action and discover all the affected victims of predatory lending from XX/XX/XXXX to this day in XX/XX/XXXX. 
The arbitration clause in question and hereby attached below, clearly stated that, If federal law provides that a claim or dispute is not subject to binding arbitration, this Arbitration Provision shall not apply to such claim or dispute. 
Therefore, the defendants enforced this arbitration provision against the plaintiff which is against the final rule on arbitration and as such the people of Virginia are formally requesting the Consumer Financial Protection Bureau to initiate a case against Lentegrity LLC and XXXX XXXX XXXX XXXX XXXX XXXX in order to rescue victims of predatory lending who have suffered from this arbitration provision since XX/XX/XXXX to this day XX/XX/XXXX. 

In that regard, the Consumer Financial Protection Bureau clearly stated that, On XXXX XXXX, XXXX, the XXXX signed a joint resolution passed by Congress disapproving the Arbitration Agreements Rule under the Congressional Review Act ( CRA ). Pursuant to the joint resolution, the Arbitration Agreements Rule has no force or effect. On XXXX XXXX, XXXX, the Bureau published a notice removing the Arbitration Agreements Rule from the Code of Federal Regulations.

The Consumer Financial Protection Bureau further states that, First, the final rule prohibits covered providers of certain consumer financial products and services from using an agreement with a consumer that provides for arbitration of any future dispute between the parties to bar the consumer from filing or participating in a class action concerning the covered consumer financial product or service, where the plaintiff asserts that the defendants and predatory lenders are part of the covered providers who are now and have been prohibited by this law since XXXX, and as a result they have not been compliant with this act because the plaintiff signed the sales contract in XXXX, which is clearly after the final rule was issued. 
The plaintiff notes that the predatory lenders, Lentegrity LLC and XXXX XXXX XXXX evidently fall under the category of service providers because they are an automobile business entity providing credit and finance options for their vehicles and their definitions are clearly set forth fully under paragraphs 5, 6 and 7 of 12 U.S. Code 5481 - Definitions.

The final rule of 12 CFR 1040 stated that, Second, the final rule requires covered providers that are involved in an arbitration pursuant to a pre-dispute arbitration agreement to submit specified arbitral records to the Bureau and also to submit specified court records. The Bureau has also adopted official interpretations to the proposed regulation.

This plaintiff argues that the defendants should submit all arbitral records to the Bureau for all the sales contracts from XXXX to XXXX, that they have successfully imposed arbitration on the consumers or in the alternative, the Bureau should order the defendants to release the information of the consumers from XXXX to XXXX so that they can be discovered and compensated accordingly. 
The plaintiff further argues that other jurisdictions have ruled on the enforceability of arbitration provisions in predatory lending disputes which includes the following notable cases : XXXX XXXX XXXX XXXX XXXX XXXX XXXX, XXXX XXXX XXXX ( XXXX ) : Respondents filed a complaint against XXXX XXXX XXXX XXXX XXXX ( " XXXX XXXX XXXX  '' ), which was later consolidated with a putative class action, alleging that XXXX XXXX XXXX had engaged in false advertising and fraud by charging sales tax on phones it advertised as free. XXXX XXXX XXXX moved to compel arbitration under the terms of its contract with respondents and respondents opposed the motion contending that the arbitration agreement was unconscionable and unlawfully exculpatory under California law because it disallowed classwide procedures. The district court denied XXXX XXXX XXXX 's motion in light of XXXXXXXX XXXX XXXXXXXX XXXX XXXX and the XXXX XXXX affirmed. At issue was whether the Federal Arbitration Act ( " FAA '' ), 9 U.S.C. 2, prohibited states from conditioning the enforceability of certain arbitration agreements on the availability of classwide arbitration procedures. The Court held that, because it " stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress, '' quoting XXXX XXXX XXXX, California 's XXXX XXXX  rule was preempted by the FAA. Therefore, the Court reversed the XXXX XXXX 's ruling and remanded for further proceedings consistent with the opinion. 
XXXX XXXX XXXX XXXX XXXX XXXX ) : Respondents were customers of XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX a XXXX XXXX registered with the Securities and Exchange Commission ( SEC ) , under customer agreements providing for arbitration of any controversy relating to their accounts. Respondents filed suit in XXXX XXXX XXXX XXXX XXXX and its representative ( also a petitioner here ) who handled their accounts, alleging violations of the anti-fraud provisions in 10 ( b ) of the Securities Exchange Act of 1934 ( Exchange Act ) and SEC Rule 10b-5, and of the Racketeer Influenced and Corrupt Organizations Act ( RICO ). Petitioners moved to compel arbitration of the claims pursuant to 3 of the Federal Arbitration Act, which requires a court to stay its proceedings if it is satisfied that an issue before it is arbitrable under an arbitration agreement. The District Court held that respondents ' Exchange Act claims were arbitrable, but that their RICO claim was not. The Court of Appeals affirmed as to the RICO claim, but reversed as to the Exchange Act claims.

The plaintiff asserts that his lawsuit against the defendants encompasses a wide range of violation of the U.S. federal laws and as such enforcing arbitration goes against the dictates of the U.S Congress and the President who signed the bill into law of the final rule amending of 12 CFR 1040 and as such sending the complaint into arbitration stood as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress and therefore it should be addressed accordingly and maximum compensation be extended to all affected victims and survivors of predatory lending from the defendants.

The plaintiff further notes that predatory lenders like the defendants, often involve unfair, deceptive, or abusive practices in connection with consumer financial products and service which are not and should not be arbitrable and therefore the Bureau have previously considered various factors when determining the enforceability of arbitration provisions in these cases, including : Unconscionability : The plaintiff clearly showed and demonstrated how the arbitration agreement was so one-sided and oppressive that it is unenforceable because the entire process was being managed and controlled by the defendant and predatory lender XXXX XXXX XXXX who was being represented by their own registered agent thus appearing as propria persona, which goes against legal norm and other jurisdictions. The plaintiff also notes that he requested for the rescheduling of the arbitration hearing, but the clerk did not acknowledge the plaintiffs request, but as soon as XXXX XXXX requested for the rescheduling of the arbitration hearing, the clerk acknowledged XXXX XXXX request which evidently shows who the arbitration agency is primarily serving their needs. The plaintiff also showed how the defendant was using threats of financial sanctions and referencing the threats issued by the XXXX XXXX to try and subdue the plaintiff into signing another predatory contract which sought to impose unnecessary arbitration fees on the plaintiff as soon as he signed the agreement that did not clarify who would be responsible for all the fees for arbitration. Therefore, this arbitration is unenforceable because it is clearly and evidently one sided where the defendant was hoping for a straight and easy win with a dismissal and further costs to be imposed on the plaintiff, but unfortunately for the predatory lenders, residents of Virginia are much smarter than they appear and as such the Bureau must stand firm with the dictates of the law and grant the plaintiffs request on the grounds of unconscionability of arbitration of this complaint.

Public policy : The plaintiff provided the provision of the law that goes against enforcing the arbitration agreement, which is the final rule of 12 CFR 1040 where further enforcing arbitration will contravene the public policy and further harm the public interest and therefore the Bureau should grant the plaintiffs request on the grounds of the dictates of the public policy where the CFPBureau amended 12 CFR chapter X by removing part 1040 and as a result, the arbitration clause under the plaintiffs sales contract is null and void. 

THEREFORE, the plaintiff XXXX XXXX claims that by their own admission of the sales contract of the defendants and predatory lenders under the arbitration provisions, the arbitration clause clearly stated that, If federal law provides that a claim or dispute is not subject to binding arbitration, this Arbitration Provision shall not apply to such claim or dispute, and as such since XXXX XXXX, XXXX, XXXX XXXX in his first term signed a joint resolution passed by Congress disapproving the Arbitration Agreements Rule under the Congressional Review Act ( CRA ) and therefore the defendants had no basis requesting for arbitration as it is against the law and as such all the consumers who have been subjected to arbitration since XX/XX/XXXX by the defendants, should be discovered and compensated accordingly with an order from the Consumer Financial Protection Bureau who also has jurisdiction to represent consumers in the XXXX XXXX 
WHEREFORE, the plaintiff respectfully files this complaint and swears under penalties of perjury that the foregoing is true to the best of his knowledge in that the defendants enforced an arbitration provision against the plaintiff which is against the final rule on arbitration and as such the people of Virginia are formally requesting the Consumer Financial Protection Bureau to initiate a case against Lentegrity LLC and XXXX XXXX XXXX XXXX XXXX XXXX in order to rescue victims of predatory lending who have suffered from this arbitration provision since XX/XX/XXXX to this day XX/XX/XXXX.

Company response to consumer: Closed with explanation