Only four comments have been received, so far, regarding the “Defining Larger Participants of the Automobile Financing Market” rule, proposed in September by the Consumer Financial Protection Bureau. The comment period opened on October 8.
This means the time in which industry and consumer advocates can submit their comments is coming to an end, with the deadline set for 11:59 PM tonight.
“Oftentimes, what will happen is that the comments will be finalized just as the deadline approaches,” Attorney John Redding, partner at Buckley Sandler LLP, told Auto Finance News. “So it’s not unusual to see a relatively small number of comments throughout the comment period and then see that number increase rather significantly, immediately before the deadline.”
The proposed rule currently proposes that companies which make, acquire, or refinance at least 10,000 or more loans or leases in a year, would be subject to CFPB supervision to ensure they are complying with federal consumer financial law.
“There are a number of areas in which we’re likely to see comments, including the threshold, the limit of 10,000 contracts,” Redding said. “I think we’ll see a number of comments that that threshold is too low. I also think that you’re going to see comments regarding securitizations and requests for clarification. And then I think you may also see comments regarding the inclusion of motorcycles in the definition of automobiles.”
Many smaller business, Redding said, are likely to suggest it is inappropriate, given the small percentage of the market they hold, to subject them to supervision, given the impact it could have on their business.