Recommendations for successful implementation of H.R. 1’s auto loan interest deductions
July 30, 2025
Implementation of provision in H.R. 1 (previously the One Big Beautiful Bill Act) allowing consumers to deduct interest on certain auto loans requires additional actions to reduce administrative burdens. In a letter to Treasury Secretary Scott Bessent sent Tuesday, America’s Credit Unions made several recommendations to support effective implementation.
These include:
- The Internal Revenue Service (IRS) should develop and publish a Model Form that credit unions and other financial institutions may use to satisfy reporting obligations. A clear template for credit unions would eliminate unnecessary confusion over required data fields, help clarify lender information requirements, and promote consistent and accurate reporting;
- Establish a safe harbor protecting credit unions that make a good-faith effort to comply with the new reporting requirements. Specifically, credit unions should not be held liable for errors or omissions when the borrower incorrectly represents the vehicle’s qualification or use and other circumstances;
- Treasury and the IRS should permit carryforward relief for taxpayers so that if a credit union member misses the deduction due to a good-faith compliance error, the unclaimed deduction may be applied in a future year; and
- Car dealerships should be responsible for verifying if a vehicle is qualified (defined in H.R. 1 as a car, minivan, van, SUV, pick-up truck, or motorcycle with a gross vehicle weight rating of less than 14,000 pounds, which has undergone final assembly in the U.S.) These metrics are not easily verifiable by credit unions.
America’s Credit Unions’ Compliance Blog has a recent entry examining the car loan interest deduction in detail.
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