On September 20, the CFPB filed individual administrative lawsuits against five auto title lenders operating in the State of Arizona. The Bureau claims that all five lenders failed to adequately disclose the annual percentage rate (APR) on their website or in online advertisements promoting title loans. For each action, the Bureau filed a Notice of Charges. A Notice of Charges is comparable to a complaint filed in federal court, but instead initiates the proceedings in an administrative forum. The cases, if they do not settle, will be tried by an Administrative Law Judge (ALJ) from the CFPB’s Office of Administrative Adjudication. The ALJ will hold hearings and offer a recommendation to CFPB Director Richard Cordray who will issue a final decision. That decision may be appealed to a federal court.