NIADA submitted formal comments to the Consumer Financial Protection Bureau (Bureau) in response to its request for feedback on the Bureau’s draft Strategic Plan for fiscal years 2025–2030.
NIADA’s comments focused on four key aspects of the draft plan.
First, the Bureau should implement new measures to identify and remove improper submissions to its consumer complaint system, allowing the Bureau to direct its attention and resources toward legitimate, actionable consumer concerns. The Bureau should not expend its limited resources by treating complaints about poor customer experiences in the same manner as allegations involving potential violations of consumer financial protection laws.
Second, and consistent with its renewed supervisory priorities from April 2025, the Bureau should shift more of its supervisory focus toward depository institutions rather than non-depository entities. By the Bureau’s own analysis, depository institutions present the most significant consumer risks and should be prioritized accordingly. This is particularly important given that independent automobile dealers already face substantial and often overlapping oversight from both federal and state regulators.
Third, the Bureau should take steps to minimize duplicative enforcement efforts when state regulators, law enforcement authorities, or other federal agencies are already actively investigating, or have completed investigations into, the same matter.
Finally, the Bureau should systematically identify and address outdated, unnecessary, or unduly burdensome regulations. As part of this effort, the Bureau should initiate a formal notice and comment process to consider raising the current activity threshold under the auto finance larger participant rule, something NIADA commented on in September 2025 in response to an advance notice of proposed rulemaking effort published by the Bureau.
NIADA appreciates the Bureau’s efforts to realign its mission and resource allocation in a manner that reduces overregulation while maintaining common-sense consumer protections. We remain hopeful that the final Strategic Plan will reflect the feedback provided in NIADA’s comments.
