Auto lenders should keep these possible changes on their radar and consult with legal experts in the event this change is implemented as proposed.
Celia Winslow, senior vice president of AFSA, told Automotive News that while the CFPB does not have jurisdiction over creditors, it is meaningful that the bureau included in its proposed amendments mention of its authority around UDAAP violations — short for unfair, deceptive or abusive acts or practices. That could allow other regulators to limit the number of calls creditors can make to customers.
And in a study published in late 2019, AFSA concluded that when phone calls to customers are restricted, not all customers are reached in time to make payments on delinquent accounts. That means there would be a higher chance of vehicle repossessions in such cases. It requires at least 30 attempts to reach up to 20 percent of borrowers in a given month, AFSA found. And approximately 11 percent of borrowers require more than 49 telephone attempts before they’re reached.