Joint Comments to CFPB on Enhancing Public Data on Auto Lending

Dear CFPB Staff,

The American Bankers Association, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, National Independent Automobile Dealers Association, National Association of Federally-Insured Credit Unions, and the U.S. Chamber of Commerce ("the Associations") are writing in response to the Consumer Financial Protection Bureau's ("CFPB" or "the Bureau") announcement regarding data on auto lending. Below, we explain that the CFPB’s announcement contains insufficient information for a thorough response, question the assumptions in the CFPB’s announcement, and list some of the many sources of auto loan data already available.

I. Insufficient Information

The CFPB's press release and attached document concerning the collection of information related to auto lending lack meaningful context, transparency, and direction. In the notice, the CFPB has not:

1. Stated the authority it is using for its request,
2. Explained what information it is looking for, nor
3. Asked any questions.

For these reasons, there is not sufficient information to enable the Associations to authoritatively respond.

Moreover, press releases are not the appropriate method for an agency to launch an initiative. A Request for Information ("RFI") would have offered a far superior framework to ask for and collect information about auto lending data. After being informed by market research, an RFI would have afforded the CFPB the opportunity to outline its findings and gaps in the CFPB’s knowledge from open market research, while explaining the data sought and its relevance to the CFPB’s goals.

Furthermore, the CFPB has initiated discussions with some groups on this topic, but has not included all stakeholders. The Associations respectfully request that the CFPB include all relevant stakeholders in future discussions. A transparent process with all necessary stakeholders is essential and in line with policymaking requirements, as well as the Bureau’s mission to make consumer financial markets work for consumers, responsible providers, and the economy as a whole.

Download the joint letter to read the full text.