America’s Credit Unions urges CFPB to retract auto loan data collection proposal

America’s Credit Unions joined with several organizations to urge the CFPB to abandon its request for comment under the Paperwork Reduction Act (PRA) regarding a proposed new information collection on auto lending, noting the bureau lacks legal authority to collect the information outlined in the proposal and “grossly underestimates the burden of the information collection.” 

The proposed new information collection – the “auto finance data project” – would annually require lenders that originate greater than 20,000 auto loans in the previous calendar year to furnish the bureau with an expansive data set including, but not limited to, at least 16 distinct data points. The proposed collection includes a burden estimate that is “so low that it suggests the CFPB does not understand the magnitude of the data request,” wrote the groups.  In the proposal, the bureau estimates that the data request will impact 4,000 respondents for an estimated total annual burden of 1,375 hours – which breaks down to 20 minutes per respondent. In the letter, the organizations outlined why this estimate is off “by a magnitude of 3,000.” 

In addition, to explain why the bureau lacks the legal authority to collect the information outlined in the auto finance data project, the groups noted the CFPB’s market monitoring provisions do not provide the bureau with the authority to conduct this data collection and, if approved, the collection would result in the unlawful gathering and analysis of personally identifiable financial information. 

The organizations also suggested the proposed collection is unnecessarily duplicative of information otherwise reasonably accessible to the bureau and the collection request is excessively burdensome. 

America’s Credit Unions will continue to engage the bureau to ensure credit unions can effectively serve their members and are not faced with overly burdensome regulatory compliance requirements. 

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