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.
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 http://www.thecre.com/insurance/?page_id=31
The Federal Focus eRulemaking.US website http://erulemaking.us/
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 http://www.thecre.com/pdf/20120809_CPRBlog.pdf
Repectfully,
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.
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.