Last week, AFSA, along with many other trade associations, submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to its announcement seeking additional information on auto lending. The letter laid out several issues with the Bureau’s request.
First, the Bureau’s press release and documentation “lack meaningful context, transparency, and direction.” Additionally, instead of using the Request for Information (RFI) process, the Bureau chose to seek information via press release which lacks the robust framework that allows stakeholders and agencies to have clear, targeted conversations regarding the topic.
Second, the CFPB has initiated discussions with some stakeholders but has failed to include all. The comment letter asks the Bureau to ensure that all relevant stakeholders are invited into future discussions.
Next, the Bureau’s announcement makes another incorrect assumptions, including that:
- Car prices have risen, leading to larger loan amounts but has not cited any information to back up the statement.
- There has been an increase in delinquencies but fails to explain that this is a correction from historically low delinquencies caused by the pandemic, and;
- Expresses concerns over the industry’s ability to conduct independent analyses, an observation that is not factual.
Finally, the letter asks the Bureau to update existing databases, namely it’s Auto Loan Dashboard, which contains much of the information the Bureau seeks. Moreover, there are numerous sources for auto loan data, including documents from the federal reserve, reports and analyses from private companies and reports from media outlets, that the Bureau can look to before initiating a likely duplicative process with industry players.
AFSA, Trades Comment on Bureau Auto Lending Announcement
Dec 28, 2022
Last week, AFSA, along with many other trade associations, submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) in response to its announcement seeking additional information on auto lending. The letter laid out… Read the rest
AFSA’s 2022 By The Numbers
Dec 19, 2022
CFPB Director Testifies Before Congress
Dec 15, 2022
Consumer Financial Protection Bureau (CFPB) Director Rohit Chopra testified before the House Financial Services Committee yesterday. Members of the committee took the opportunity to address concerns over the Bureau’s use of a long dormant… Read the rest
CEO IMPERATIVES: 2023 PRIORITIES & PREDICTIONS
Dec 14, 2022
AFSA’s great strength is the depth and breadth of the knowledge and expertise of our members; that expertise that will be on display at the 2023 Vehicle Finance Conference & Expo with our famous CEO Panel.
Our industry leaders … Read the rest
CFPB Proposes Nonbank Registry
Dec 13, 2022
This week, the Consumer Financial Protection Bureau published a proposed rule called Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders. According to the proposed rule, the Bureau would require covered entities… Read the rest
On Partnerships: The Fast Track To Innovation And Efficiency
Dec 08, 2022
Join us today at 2:00 p.m. for On Partnerships: The Fast Track To Innovation And Efficiency, sponsored by defiSOLUTIONS.
What can or should vendors do as partners to deliver market-changing technology and innovations? Join long-time industry… Read the rest
LISTEN | Fraud Isn’t What You Think
Dec 07, 2022
In this episode of the AFSA Extra Credit Podcast, Dan chats with Justin Davis, VP of Product Delivery and Frank McKenna, Chief Strategist with Point Predictive about the uptick in fraud as we come out of the pandemic and navigate a turbulent … Read the rest
The Economy of Policy & Politics
Dec 07, 2022
Want the skinny and insights on what Congress may do in the coming year in response to an uncertain economic, regulatory and political environment?
Join a panel of one of Washington’s most senior and accomplished Capitol… Read the rest
AFSA Comments on Inflation Reduction Act
Dec 07, 2022
Earlier this month, AFSA responded to a joint Department of Treasury (Treasury) and Internal Revenue Services (IRS) request for comment and participated in a Treasury roundtable on Clean Vehicles and the “Inflation Reduction Act” (IRA).… Read the rest
WHAT RESILIENT TEAMS GET RIGHT with Michael Lombardi
Dec 06, 2022
AFSA is pleased to announce three-time NFL Super Bowl champion executive and commentator Michael Lombardi as its keynote speaker for its 2023 Vehicle Finance Conference at the historic Hilton Anatole Hotel in Dallas, sponsored … Read the rest