The Center for Responsible Lending, Consumer Federation of America, Consumers for Auto Reliability and Safety, the National Association of Consumer Advocates, the National Consumer Law Center, and on behalf of its low-income clients the National Council of La Raza have filed the following comments to the FTC in regards to auto financing and the recent motor vehicle roundtables held across the country.

This case involves borrowers who purchased a vehicle through a dealership in California. The financial institution in question, Wachovia, did not make the loans, but later purchased the installment contracts from the dealer. When the borrower fell behind on their payments, Wachovia repossessed the cars without properly following California law. California allows self-help repossession, but has strict rules regarding consumers’ rights in repossession, including the notices that a creditor must send to consumers.

CRL and the National Consumer Law Center filed an amicus brief supporting appellant Donna Epps in regards to the improper repossession of the appellant's vehicle.

New report from CRL highlights a 24 percent increase in dealer rate markup volume to $25.8 billion per year; reveals a higher interest rate markup for consumers with weaker credit; links higher default and repossession rates among subprime borrowers to dealer rate markups.

Predatory practices in auto financing cost consumers billions of dollars every year. Finding a good deal is no longer based on the quality of the car or the creditworthiness of the customer, but rather the customer’s ability to survive a financial shell game by the dealer. This brief unveils some of the most common abuses in dealer-financed loans.

The auto dealer lobby successfully fought to receive a special exemption in the House from the rules of the Consumer Financial Protection Bureau (CFPB) in the financial reform bill even when the dealers act as creditors and brokers on car loans. But fair, honest and ethical competition requires a level playing field, as well as a fair and consistent system for accountability.

For the final financial reform bill that will be considered and voted on by the House and Senate joint conference committee, there are three issues vital in protecting taxpayers from another crisis in the future.

A brief by the National Consumer Law Center shows state-by-state markups on auto loan rates by race, revealing wide disparities between costs for African-American and white car buyers.

Consumer Advocates and The Pentagon Call for all Auto Dealer-Lenders to be Covered by Consumer Watchdog.

The Military Coalition expressed opposition via letter to the Senate Banking Committee about exempting car dealers from the financial reform bill on April 15 2010. The Department of Defense wrote a similar letter in February 2010 because car dealers have abused servicemembers.