
On Feb. 28, the American Financial Services Association (AFSA) submitted a comment letter to the New York City Department of Consumer Affairs regarding the Department’s proposed rules for secondhand auto dealers.
The proposed rules would implement Local Laws 197 and 198 of 2017, which passed the City Council in September. The laws and proposed rules set certain requirements for secondhand auto dealers in the city, including disclosure of car buyer’s bill of rights.
In addition to disclosure of the contract APR, there is a requirement to disclose the lowest APR offered to a buyer by any finance company for a loan with same term and down payment and the APR offered to a buyer by the selected finance company.





