AFREF joined partners in submitting comments to the CFPB in response to their initiative to enhance public data on auto lending. The letter states that in order to address many of the current deficiencies in our knowledge of the auto finance marketplace, the CFPB should:
Collect data from a broad variety of sources that reflects the broad array of credit
transactions and creditors, and which focuses on the consumer experience rather than
Ensure that auto lending data is publicly available and usable, as granular as possible, and
updated on a regular basis.
Collect transaction level data about origination, consumer payment performance, and the
entire repossession process from beginning to end.
Collect data about consumer demographics, including race, ethnicity, age, gender, and
Collect data about Buy-Here-Pay-Here finance entities, and subprime and regional