AFSA Comments on Legislation Regulating Payment Assurance Devices April 10, 2018 On April 10, AFSA submitted a comment letter to the Illinois Senate Judiciary Committee in opposition to Senate Bill 2521, which would create certain conditions for the use of electronic tracking technology or starter interrupt technology in connection with the credit sale, loan, or lease of a motor vehicle. The bill was scheduled for consideration at a hearing later that day. AFSA’s letter explained that these devices provide an alternative to physical repossession of a vehicle and allow financial institutions to make financing available to consumers who might not otherwise be able to obtain it. The proposed legislation would treat the use of this technology as a repossession under the Uniform Commercial Code; AFSA’s letter highlighted the key differences between physical repossession and the use of payment assurance devices and requested that any legislation must recognize this distinction and treat each process accordingly. Additionally, the letter noted that the bill’s proposed data protection requirements would create additional unnecessary burdens, with no added consumer benefit, for data already protected by federal law and existing industry best practices. Seven other groups also registered opposition to the bill, including the Illinois Financial Services Association and the Independent Finance Association of Illinois. The Judiciary Committee voted to pass SB 2521 following the hearing, but the bill’s sponsor has indicated a willingness to work with industry to amend the bill to address concerns. The deadline for Senate bills to pass the full chamber is April 27. AFSA will continue to monitor the process and keep members apprised of any future changes to the proposed legislation.