LAS VEGAS – In June, senior manager with the Consumer Financial Protection Bureau offered an update on an auto lending data project the bureau has been working on since last year. Corinne Kirkendall, Passtime’s executive vice president of compliance affairs, moderated the discussion with Chris Kukla, a senior program manager for CFPB, during a session at the National Independent Automobile Dealers Association Convention & Expo in Las Vegas.

Kukla’s role includes engaging with industry stakeholders throughout the industry. “I want to encourage you,” he said, “My door is always open. It’s not a fishing expedition. I’m really trying to understand the industry.”

Kukla, who comes from a background in consumer finance, cited what he feels is an important feature of the bureau. “One of the things I appreciate about the CFPB is we are a data-driven agency,” he said. “We dig deep into data.” CFPB draws its data from several sources, such as its own Consumer Credit Panel – a sample from a large credit reporting agency – as well as information from places like Experian and Moody’s S&P, for example, Kukla said.

Kirkendall zeroed in on the data issue and asked about the CFPB’s “Auto Finance Data Pilot.”

The project was announced last November to look at potential data gaps within the auto finance space and find ways that CFPB could help fill those gaps, Kukla said. One goal was to make more information available to stakeholders across the whole industry. “So, we held an all-day event in December where we heard from stakeholders across the industry about what data is available and what data is not available,” Kukla said. “Also, where are the areas where there is strong visibility?”

For instance, the CFPB knows what’s going on in the area of delinquencies, because there are a lot of different places where it can find delinquency data. “With repossessions? There’s not a lot of visibility in repossessions,” Kukla said. “There’s nobody who actually collects and publishes how many repossessions are happening across the United States.”

This was one area the stakeholders at the December meeting discussed. They felt it would be helpful to know what’s going on with repos and have a standard, regular data point on repossessions, Kukla said. “How many are happening?” Kukla said. “Where are they happening? What does the trajectory look like in terms of 30-, 60-, 90-day delinquencies going into repossession?”

Over the last couple of years in the wake of big COVID payments, there have been higher than average cure rates. Consumers have been staving off repossessions. “We know that may start to slow down, but we don’t have the data to back that up,” Kukla said. “A lot of that is just from conversations we’re having with folks who are willing to share what’s going on."

“That’s certainly helpful, but it’s not actionable data that we can all agree on, look at and say, ‘Yes, this is what’s happening in the market.’”

As a result of the meeting last year, CFPB asked people to submit comments on identifying the areas that the industry needs greater visibility on in the data space.

Next came the need for the data itself.

“In February, we announced that, as a first step in the process of this data collection, we issued what we call 1022 orders,” Kukla said. These orders come from Dodd-Frank act, providing the bureau with authority to ask for information from lenders.

The CFPB made the order public and sent it to nine different lenders, Kukla said.

The bureau explained in a blog post last February – which Kukla helped draft – that data collected from lenders’ responses to these orders will help CFPB build a quality data set that provides insights into lending channels, loan performance, and inform potential future data collection efforts.

The December discussions identified three areas where most participants stated that additional data visibility would be important: lending channel differences; data granularity, consistency, and quality; and loan performance trends. 

At the NIADA event, Kukla said the data was still coming in and it would take time to compile and analyze it.

“I would expect that sometime in the fourth quarter, we’ll have more announcements about what we’re seeing in that data and what some next steps might be,” he said. 

However, CFPB will not be sharing the raw data since it is confidential data from lenders, Kukla said.

“What we release will be aggregated data that will be anonymized so folks won’t be able to identify who the particular lenders would be,” he said. “But we are going to provide – at least at the outset – some topline findings of what we have.”

When the final data is released, the CFPB will be clear about common definitions for different credit tiers, such as what defines a subprime borrower, Kukla said.

As part of this process, one thing the CFPB is hoping to do, if possible, is provide a regular set of data that offers some visibility into the market to help all stakeholders better understand what’s happening in the auto finance market, whether it’s auto lenders, consumer advocates or the general public, Kukla said.