Five industry associations recently sent a 14-page letter to the Consumer Financial Protection Bureau (CFPB), pushing back against the regulator’s request for more information regarding collections and vehicle repossessions by auto finance companies.

Part of what troubles these associations is that the CFPB is now seeking information for its Auto Finance Data Project from providers who book as few as 500 installment contracts annually.

The associations are urging the CFPB to abandon the new information collection because:

—The CFPB lacks the legal authority to collect the information

—The CFPB grossly underestimates the burden of the information collection

Writing and sending this letter were the American Bankers Association, American Financial Services Association, America’s Credit Unions, Consumer Bankers Association and U.S. Chamber of Commerce

The associations pointed out that the CFPB previously asked nine finance companies to provide a “substantial” amount of data for all financing originated or serviced over a five-year period.

The requested data included, but was not limited to, the following:

—Total price of the vehicle

—All fees

—Any voluntary products

—All contract terms

—Dealer reserve amount

—Both the loan-to-value and payment-to-income ratios

—Brand of vehicle

—Whether the vehicle was new or used

—Information on the dealer

—Information on the consumer such as credit score and income,

—Military status of the consumer

—Information on the co-signer

—Information on whether the contract was paid off,

—Whether the vehicle was repossessed

—Any information about that repossession

—Consumer complaints.

“The CFPB also proposes to collect annually a more limited data set from lenders that originated greater than 500 loans and fewer than 20,000 loans in the previous calendar year. These lenders would be required to submit information on the number of vehicles repossessed and the number of loan modifications,” the associations wrote.

“However, the CFPB’s notice does not include the survey instrument to be used in this newly proposed collection. Instead, the bureau simply states that the collection will mirror the Data Pilot. The lack of access to the survey instrument for this new information collection significantly impedes the associations’ ability to offer comments and address the questions posed by the CFPB in the notice,” the associations continued.

“Based on the aforementioned reasons, the CFPB should retract the notice and discontinue its pursuit of approval for this collection until it has unequivocally identified the appropriate authority for conducting it, ensured compliance with the Paperwork Reduction Act (PRA), and undertaken a thorough effort to accurately assess the estimated burden associated with the proposed data collection,” they went on to write. “Office of Management and Budget (OMB) should withhold approval until these essential initial steps have been completed. The associations stand prepared to offer insights from the auto financing market in response to any subsequent notices, adhering to a timeframe and process consistent with the PRA and the bureau’s statutory authority.”