Joint Trades Letter to CFPB Regarding Enhancing Public Data on Auto Lending

The American Bankers Association, American Financial Services Association, Consumer Bankers Association, Credit Union National Association, National Independent Automobile Dealers Association, National Association of Federally-Insured Credit Unions, and the U.S. Chamber of Commerce (“the Associations”) are writing in response to the Consumer Financial Protection Bureau’s (“CFPB” or “the Bureau”) announcement regarding data on auto lending. Below, we explain that the CFPB’s announcement contains insufficient information for a thorough response, question the assumptions in the CFPB’s announcement, and list some of the many sources of auto loan data already available.