AFSA’s State Government Affairs team recently submitted a comment letter on California’s Department of Financial Protection and Innovation Debt Collection Licensing Act. AFSA and the California Financial Services Association (CFSA) provided comments to the Department of Financial Protection and Innovation (DFPI) regarding the proposed scope rule under the Debt Collection Licensing Act. While appreciating steps toward clarification, we remain primarily concerned that the proposed regulation fails to properly address the role of indirect automobile financing in California.
We argue that indirect auto finance companies should be considered 1st Party Creditors under the exemption, aligning with federal law, and recommend using charged-off debt (instead of 90 days past due) as the trigger for certain requirements.
This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.
AFSA Urges Clarity on Debt Collection Act
Dec 18, 2025
AFSA’s State Government Affairs team recently submitted a comment letter on California’s Department of Financial Protection and Innovation Debt Collection Licensing Act. AFSA and the California Financial Services Association… Read the rest
NY Fed: Rate Caps Don’t Work
Dec 18, 2025
A recent working paper issued by the Federal Reserve Bank of New York, Less for You, More for Me: Credit Reallocation and Rationing Under Usury Limits, delves into the age old question of the efficacy of usury limits, i.e., interest rate caps.… Read the rest
AFSA Submits Comment Letter on Small Business Lending Data Collection Proposal
Dec 17, 2025
Earlier this week AFSA submitted comments on the CFPB’s proposal to change small business lending data collection requirements established under Section 1071 of the Dodd-Frank Act (the 1071 Rule). This proposal contemplates streamlining… Read the rest
AFSA Supports Major Bipartisan Housing Legislation
Dec 17, 2025
AFSA is pleased to support the bipartisan Housing for the 21st Century Act, which will boost housing supply, improve affordability, and streamline existing regulations for millions of Americans.
Thanks to House Financial Services Committee… Read the rest
AFSA C3 Index
Dec 11, 2025
AFSA’s Consumer Credit Conditions (C3) Index for the third quarter of 2025 revealed a challenging quarter for consumer lenders offset by growing optimism about business conditions over the next six months. The survey of AFSA member companies… Read the rest
CFPB Funding
Dec 11, 2025
In a new letter to President Trump and congressional appropriations committee leaders, the CFPB’s Acting Director Russell Vought wrote that the Bureau will need $279 million next year to maintain its required activities. … Read the rest
Industry Expertise | How Lenders Can Innovate with AI Without Increasing Regulatory Risk
Dec 10, 2025
“Industry Expertise” is sponsored content produced by AFSA’s Business Partners’ to provide thought leadership and best practices for AFSA member companies. For more information about this sponsored content opportunity, contact Dan … Read the rest
AFSA in American Banker
Dec 09, 2025
We appreciate the American Banker’s coverage of our exclusive Consumer Credit Conditions (C3) Index, which we release quarterly.
The C3 Index is designed to highlight the crucial role the consumer credit industry plays in the broader
AFSA Economist Shares Thoughts on Economic Outlook
Dec 03, 2025
AFSA Chief Economist Tim Gill recently took part in a panel discussion on economic and automotive industry trends at Used Car Week 2025. The panel “Inside Automotive & the Economy,” was moderated by Nick Zulovich of Cherokee Media Group… Read the rest
A New CFPB Nomination
Nov 20, 2025
Clarity and certainty in the public policy space has long been a priority for the American Financial Services Association, which is why we appreciate the recent nomination of Stuart Levenbach to serve a five-year term as director of the Consumer… Read the rest