March 25, 2024 — Comments

Consumer groups applaud the Consumer Financial Protection Bureau (CFPB) effort to improve the collection and dissemination of auto finance data as part of its efforts to monitor the auto finance market for risks to consumers. The CFPB should:

  • Collect information that reflects the broad array of credit transactions and creditors, including Buy-Here-Pay-Here, smaller subprime, and regional financing entities;
  • Include finance entities that originate fewer than 500 auto finance transactions per year and other entities that hold auto related debt;
  • Collect specific data from BHPH dealers;
  • Collect data from other entities that hold auto debt;
  • Ensure that the data collected is publicly available and usable in as granular a condition as possible, and is updated on a regular basis;
  • Collect data about lease transactions that allows the analysis of the consumer market risks created by the leasing market; and
  • Consider ways to collect data about consumer demographics, including race, ethnicity, age, gender, and other characteristics.