End CFPB Vehicle Finance Supervision

End CFPB Vehicle Finance Supervision

On September 22, 2025, AFSA submitted a comment letter in response to the CFPB's advance notice of proposed rulemaking (ANPR) on supervision of vehicle finance companies. The ANPR asked for thoughts on changing the way the CFPB supervises non-bank vehicle finance companies.

Under the Dodd Frank Act, the CFPB is allowed to impose supervision on non-bank companies that are larger participants in a market for a given consumer financial product or service. The CFPB invoked this authority on vehicle finance companies in 2015 and set the threshold for supervision to capture companies originating more than 10,000 retail finance or lease contracts annually. This low threshold resulted in supervision on many companies.

This year, the CFPB invited comments on whether this threshold should be increased. AFSA commented, stating that there are excellent reasons to cancel this form of supervision altogether. Eliminating this supervision would allow the CFPB to focus on the priorities it has published, adhere to the tasks established under the Dodd Frank Act, and eliminate unnecessary and duplicative supervision.

Whether provided by banks or non-bank companies, vehicle finance products are well regulated at the state and federal levels and no company should be singled out for extra scrutiny by virtue of choosing to serve the vehicle finance market.

September 25th, 2025