Unfair and Deceptive Acts and Practices: 10.5.3.1 General
Another way to finance a purchase is for the seller to arrange for financing that is directly provided by a third-party lender. Then that lender is not the seller’s assignee and under common law does not step into the shoes of the seller. Nevertheless, the FTC Holder Rule generally applies to this transaction and makes the lender or the lender’s assignee subject to all claims and defenses the consumer can raise against the seller.