AFSA Comments on CFPB Proposal for an Auto Loan Survey
On March 18, 2025, AFSA submitted a comment letter in connection with the CFPB’s proposal to launch an Auto Loan Survey. This proposal was issued on January 17, 2025.
The proposal is unusual because it seeks subjective information about consumer’s opinions about matters that are outside of the CFPB’s authority. In particular, this survey intends to gather information on “the consumer’s experience related to auto purchases and loan including choosing a vehicle and financing, experiences with major vehicle expenses, experiences with loan servicing, and, if applicable, loan modification and repossession.” While vehicle financing may be pertinent to the CFPB, how consumers choose cars or deal with repair bills is not.
AFSA’s letter also makes the point that the CFPB is not exactly starved for data. It gathers data from supervision and enforcement activities, as well as the complaint portal it operates. And even if the amount of data about vehicle finance were inadequate, the proposed survey does not explain why additional subjective data about consumer opinions would be necessary for the CFPB to perform its functions.
AFSA will continue to monitor this to see if the Auto Loan Survey is actually launched.
March 19th, 2025
Recent Posts
- LISTEN | The Presidents’ Podcast
- AFSA Has a List … Wants it Checked Twice
- AFSA Comments on CFPB Proposal for an Auto Loan Survey
- AFSA Comments on IRS Commercial Clean Vehicle Tax Credit Rule
- THIS THURSDAY | AFSA Webinar | Transform Your Auto Finance Strategy: Mastering Margin Management in Uncertain Times