American Financial Services Association (AFSA)
American Financial Services Association (AFSA)OpposeTrade association
Summary: The American Financial Services Association (AFSA), a trade association for the consumer credit industry, opposes the proposed definition of "commitments" in the regulatory capital rule. They argue that the new definition would force banks to hold capital against conditional offers in the indirect vehicle finance market, leading to increased costs for consumers, reduced competition, and inconsistent capital treatment based on subjective estimates.
On behalf of the American Financial Services Association (AFSA), please see the attached comment letter.