Let’s Regulate “Surveillance Pricing”
AFSA’s State Government Affairs team submitted a comment letter opposing IL SB 2255, which seeks to regulate the use of “surveillance pricing.”
This is broadly defined to include the use of consumer data in setting prices, but the bill’s sweeping and ambiguous language could unintentionally capture common and pro-consumer practices used throughout the financial services industry.
AFSA raised concerns that the bill may restrict risk-based pricing, which is fundamental to expanding access to credit, particularly for non-prime borrowers. Limiting the ability to price based on risk could lead to reduced credit availability, higher costs for some consumers, and a shift toward less regulated lending alternatives. AFSA also noted that the bill lacks clear definitions and guardrails, creating uncertainty for compliance and increasing the risk of inconsistent enforcement.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
April 16th, 2026
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