Skip to main content

Search form

Recommendations for Improving the Research Methodology of the Proposed FTC Auto Consumer Survey

March 7, 2016
Auto Loans
Comment Letter

Cars are the most common nonfinancial asset held by American families, and for some families, their most significant asset. Cars have become a necessity for U.S households, with more than 85% of the U.S. workforce using an automobile to commute to work. Car ownership is no longer a luxury but is a prerequisite to economic opportunity. The need for a car is particularly true for many low- and moderate-income families (LMI) and communities of color, who live or work beyond the reach of public transit systems. Given the role that cars play in the everyday lives of American families, we applaud the FTC for proposing a survey to explore issues around automobile purchases and financing. The issues raised in the FTC's and Consumer Financial Protection Bureau's (CFPB) 2011 Roundtables persist in auto financing today.

Research and data have continued to illuminate potentially unfair and abusive conduct in the market. In-depth interviews will shed additional light on these abusive practices. Often, individuals are not aware they are being treated differently by dealers and lenders, and as such, interviews are a helpful tool to probe for information about a consumer’s treatment and experience. This research will bolster efforts to understand the discrimination that communities of color experience and the ways that LMI families experience different treatment. This information should help further shape the map for enforcement and regulatory efforts.