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CFPB Ramps Up Auto Finance Scrutiny: A Look at the New Data Collection Initiative

By Moorari Shah, A.J. Dhaliwal, Mehul Madia & Beineng Zhang on February 23, 2024
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In a move to bridge significant data gaps identified through its February 2023 Auto Finance Data Pilot where it sent information requests to nine large auto lenders about their lending portfolios, the Consumer Financial Protection Bureau is requesting comments for the collection of additional auto financing data. As with its prior requests, the Bureau is issuing these orders under its market monitoring authority which allows it to “gather information from time to time regarding the organization, business conduct, markets, and activities of covered persons and service providers.” 12 U.S.C. C. § 5512(c)(1) & (4). Compliance with the requests is mandatory.

The two-fold annual data collection process includes:

  • Comprehensive data from large lenders. Lenders originating over 20,000 auto loans in the previous year will submit comprehensive loan-level data, mirroring the original order’s scope.
  • Limited data from smaller lenders. Lenders with 500 to 20,000 loan originations will report on specific metrics like the number of vehicles repossessed and the number of loan modifications.

Putting it into Practice: With an estimated 4,000 auto finance companies on its radar, the Bureau’s expanded request is designed to collect a wealth of information that will enhance the CFPB’s ability to monitor the auto finance market for risks to consumers. As we discussed previously (here, here, and here), the Bureau is focused on the rise of auto prices and the impact it has had on borrowers’ loan amounts, monthly payment amounts, delinquencies and repossessions. The Bureau is also seeking to learn more about auto lenders that operate in the subprime space and that offer vehicle add-on products. As we have seen with this CFPB, market monitoring orders are often a precursor to formal rulemaking. Accordingly, auto lenders should pay careful attention.

Photo of Moorari Shah Moorari Shah

Moorari Shah is a partner in the Finance and Bankruptcy Practice Group in the firm’s Los Angeles and San Francisco offices.

Read more about Moorari ShahEmail
Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Mehul Madia Mehul Madia

Mehul Madia, special counsel in the firm’s Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

Read more about Mehul MadiaEmail
Photo of Beineng Zhang Beineng Zhang

Beineng Zhang is an associate in the Finance and Bankruptcy Practice Group in the firm’s Orange County office.

Read more about Beineng ZhangEmail
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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