CFA joined comments drafted by the National Consumer Law Center supporting the CFPB’s Auto Lending Data initiative. In November 2022, the CFPB announced that it was initiating a pilot project to collect auto finance data from nine large auto creditors. In February, it announced its intention to expand this pilot project, annually collecting data from creditors that originated between 500 and 20,000 finance contracts in the prior year. CFA and the other groups support this effort, but urge the CFPB to also obtain data from creditors that originate fewer than 500 contracts per year to ensure the Bureau can study the buy-here-pay-here marketplace.