Senators challenge CFPB on indirect auto finance guidance

BuckleySandler LLP

On October 30, a bipartisan group of 22 Senators sent a letter to the CFPB raising concerns about CFPB guidance affecting the indirect auto financing market and auto dealers’ ability to negotiate retail margins with consumers. The guidance at issue, contained within CFPB Bulletin 2013-02, advised bank and nonbank indirect auto financial institutions about compliance with federal fair lending requirements in connection with the practice by which auto dealers “mark up” the financial institution’s risk-based buy rate and receive compensation based on the increased interest revenues.

An Interactive Public Docket for the CPFB Auto Finance Program?

CFPB eRegs Team:
Accolades to you for taking actions to improve public access to CFPB  regulatory information.
We at the Center for Regulatory Effectiveness(CRE), in conjunction with our affiliate Federal Focus, have been working on similar projects for a number of years.
We have under consideration  the establishment of  an Interactive Public Docket (IPD) on  one of your ongoing regulatory programs.
Even in  the event we do not proceed you might be interested in learning of our experiences on the  use of eRulemaking.
Consequently I am providing you with background information  on CRE  Interactive Pubic Dockets:
The CRE Federal Financial Forum IPD
The  Federal Focus   eRulemaking.US   website
 CRE is one of the nation’s preimier regulatory watchdogs so it is incumbent upon us to present the views of all parities on a a particular issue; here is a view of a stakeholder who is not supportivie of the use of CRE  Interactive Public Dockets in rulemaking  please see

CFPB responds to lawmaker letters

Editor’s  Note:   There is a  question as to whether the CFPB is living up to the transparency requirements of the Obama Administration with respect to disseminating for  public comment it underlying methodlogy to use the proxy methods described below.

Automotive News
November 4, 2013 – 6:19 pm ET

WASHINGTON — The Consumer Financial Protection Bureau on Monday gave more clues about the methods underpinning its claims that auto dealers engaged in bias in setting interest rates for car loans. But the National Automobile Dealers Association says the agency didn’t provide the answers that its members were looking for.