December 19, 2022 — Comments

Auto credit and cars in general have an enormous impact on the majority of households, and auto credit is the third largest consumer credit market in the United States. Yet publicly available data is minimal and often excludes important portions of the marketplace and important details of the transactions—details that impact performance of the credit and success for consumers.

The data is also highly aggregated, making it almost impossible to evaluate in a meaningful way. The opaqueness and asymmetry of information regarding data in the auto finance marketplace in many ways mirror the opaqueness and asymmetry of information between consumers and finance personnel in the finance and insurance “F&I” office at a dealership.


These comments are submitted by the Americans for Financial Reform Education Fund, Consumer Action, Consumer Federation of America, Consumers for Auto Reliability and Safety, Center for Responsible Lending, National Association of Consumer Advocates, National Consumer Law Center, on behalf of its low-income clients, UnidosUS and U.S. PIRG.