On September 22, 2025, the American Financial Services Association (AFSA) submitted a comment letter in response to the Consumer Financial Protection Bureau’s (CFPB) advance notice of proposed rulemaking regarding supervision of vehicle finance companies. The CFPB had sought public input on whether to change how it supervises non-bank vehicle finance companies.
The Dodd-Frank Act allows the CFPB to supervise non-bank companies that are significant participants in certain consumer financial markets. In 2015, the CFPB used this authority for vehicle finance companies and set a threshold at more than 10,000 retail finance or lease contracts annually. This threshold resulted in many companies coming under CFPB supervision.
In its recent comment, AFSA argued that there are strong reasons to eliminate this form of supervision entirely. According to AFSA, removing such oversight would enable the CFPB to focus on its stated priorities and core tasks under the Dodd-Frank Act while avoiding redundant regulatory measures.
AFSA also emphasized that both banks and non-bank entities providing vehicle finance products are already subject to regulation at both state and federal levels. The association stated: "Whether provided by banks or non-bank companies, vehicle finance products are well regulated at the state and federal levels and no company should be singled out for extra scrutiny by virtue of choosing to serve the vehicle finance market."