November 17, 2015

TO THE MEMBERS OF THE U.S. HOUSE OF REPRESENTATIVES:

The U.S. Chamber of Commerce, the worlds largest business federation representing the
interests of more than three million businesses of all sizes, sectors, and regions, as well as state
and local chambers and industry associations, and dedicated to promoting, protecting, and
defending Americas free enterprise system, strongly supports H.R. 1737, the Reforming CFPB
Indirect Auto Financing Guidance Act, and H.R. 1210, the Portfolio Lending and Mortgage
Access Act.
H.R. 1737 would change the Consumer Financial Protection Bureaus (CFPB) approach
to the indirect auto lending market, and bring much-needed transparency. The CFPB has created
enormous uncertainty in this market by issuing guidance without notice and comment, and
undertaking enforcement and supervisory actions based upon post hoc statistical modelsbut
has failed to share its analysis and assumptions, thus depriving lenders of the ability to anticipate
the CFPBs analysis and to comply accordingly. H.R. 1737 would establish clear rules and put
any guidance regarding indirect auto lending on a solid footing by eliminating any legal effect of
the CFPBs 2013 guidance, and then imposing reasonable conditions on any future guidance on
this topic.
The Chamber supports H.R. 1210, which would provide regulatory certainty to lenders
particularly small lenders such as community banks and credit unionsby allowing loans held
on the books of a lender to be eligible for the safe harbor provided under the Qualified Mortgage
(QM) rule. It would also correct the CFPBs one-size-fits-all approach for the mortgage
market. H.R. 1210 would facilitate a robust underwriting process by lenders and would also help
qualified borrowers obtain mortgages by alleviating some of the uncertainty that currently exists
under the QM rule.
Collectively, these bills would provide clear rules and establish certainty in the
marketplace benefiting consumers and businesses. The Chamber urges the House of
Representatives to pass these bills as expeditiously as possible.
Sincerely,

R. Bruce Josten