AFSA Comments on New York City Proposed Rules for Secondhand Auto Dealers February 28, 2018 On February 28, AFSA submitted a comment letter to the New York City Department of Consumer Affairs regarding the Department’s proposed rulesfor secondhand auto dealers. The proposed rules would implement Local Laws 197 and 198 of 2017, which passed the City Council in September. The laws and proposed rules set certain requirements for secondhand auto dealers in the city, including disclosure of car buyer’s bill of rights. In addition to disclosure of the contract APR, there is a requirement to disclose the lowest APR offered to a buyer by any finance company for a loan with same term and down payment and the APR offered to a buyer by the selected finance company. AFSA’s letter urged the Department to reconsider its proposed disclosure form and pointed out that the disclosure of up to three different APRs may confuse consumers. The letter also noted that the Federal Reserve Board previously considered and specifically decided against requiring a similar disclosure of fees for dealer participation due to the minimal consumer benefit. The Department formally presented the rules and accepted feedback at a February 28 hearing. AFSA will continue to monitor the rulemaking process and keep members apprised of any future changes.