With the Federal Trade Commission gearing up for a potential survey of consumers who recently bought a vehicle and financed that purchase through a dealer, the American Financial Services Association and the Consumer Bankers Association recently submitted a letter to the agency asking seven specific questions about what the regulator plans to do.

Stemming from concerns that there may be an element of bias in the survey that the FTC is proposing, AFSA shared the document the organization along with the CBA delivered to the regulator in its latest edition of Newsbriefs. AFSA executive vice president Bill Himpler and CBA regulatory counsel Kate Larson authored the letter that touched on what the organizations described as “the importance of objectivity” as well as “separating research and enforcement.”

Both AFSA and the CBA are hoping the FTC can answer these questions before proceeding:

1. What is the reason for this qualitative research project at this time?

2. Are additional phases of this project contemplated, and if so, what and when?

3. What is the relationship between this presumably preliminary part of the project and future phases?

4. What specific questions or issues will be investigated at each stage of the project?

5. What is the relationship of questions asked to documents to be collected? If, somehow, consumers’ responses and documents are to be related to some sort of enforcement regime, how will there be confidence that the experiences are accurately remembered and correct?

6. What is the purpose of purported diversity in the sample? There are enough proposed different dimensions to the proposed survey of forty or eighty individuals (credit score, race, sex) that there will be very little data for comparisons among subgroups (five or 10 individuals, depending on number of interviews, in each of eight subgroups). Under the circumstances, how will the diversity be useful to the research?

7. How are results of this project to be distributed and to whom?

Himpler and Larson closed the letter by writing, “We are not concerned about estimates, or methodology in making estimates, of ‘burden hours,’ as required by the Paperwork Reduction Act since the survey is voluntary (and, presumably, paid). We are much more concerned about the real burden on honest and law-abiding automobile dealerships, financing sources, and personnel if this project is not undertaken in an objective manner.”