On March 18, 2025, the American Financial Services Association (AFSA) submitted a comment letter regarding the Consumer Financial Protection Bureau's (CFPB) proposal to initiate an Auto Loan Survey. The CFPB issued this proposal on January 17, 2025.
The proposal aims to collect subjective information about consumer opinions on matters that fall outside the CFPB's jurisdiction. Specifically, it seeks to gather insights into "the consumer’s experience related to auto purchases and loan including choosing a vehicle and financing, experiences with major vehicle expenses, experiences with loan servicing, and, if applicable, loan modification and repossession." While aspects of vehicle financing are relevant to the CFPB's mandate, how consumers select vehicles or manage repair costs is not within its purview.
AFSA highlighted in its letter that the CFPB already has access to extensive data through supervision and enforcement activities as well as its complaint portal. Moreover, even if there were insufficient data on vehicle finance, AFSA questioned why additional subjective consumer opinion data would be necessary for the CFPB's operations.
AFSA intends to continue monitoring developments to determine whether the Auto Loan Survey will proceed.