The Consumer Financial Protection Bureau’s (CFPB) announcement regarding auto lending data contains insufficient information and leads to questions about the bureau’s assumptions, CUNA and other organizations wrote to the CFPB. The CFPB issued a press release with an attached document concerning the collection of information related to auto lending.  

“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,” the letter reads. “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,” it adds.

CUNA also notes that while the CFB has initiated discussions with some groups on this topic, it has not included all relevant stakeholders in these discussions, and should do so.

The letter also notes incorrect assumptions in the CFPB’s release, including noting the auto market has seen “substantial and rapid change” without citing data other than prices. It also notes an increase in auto loan delinquencies but fails to note that is a correction from historically low delinquencies during the pandemic.

The organizations also propose the CFPB update its auto loan dashboard to include some of the many sources for auto loan data used by industry participants,