On March 10, the Congressional Research Service (CRS) published an overview of the U.S. automobile loan market. The report noted that auto loans constitute the second-largest consumer credit market after mortgages, with 108 million outstanding loans totaling $1.67 trillion as of the end of 2025. The report identified that vehicle price increases between 2020 and 2022 were primarily caused by inflationary pressures and supply chain disruptions. Such increases resulted in an uptick in the number of auto loans and average loan size. Additionally, the report underscored that rising interest rates have contributed to higher average monthly payments, increased from an average monthly payment of $470 in 2020 to $600 in 2023. Moreover, the average loan term has also increased, likely due to consumers extending loan terms to better manage payments. However, these longer loan terms could increase the share of loans with negative equity as automobiles decline in value. The report observed that the percentage of auto loan balances 90 or more days delinquent increased from 3.7 percent in the fourth quarter of 2022 to 5 percent in the third quarter of 2025, with CRS citing research from the Fed linking the spike to subprime and near-prime borrowers.

CRS clarified that, while the CFPB’s rulemaking, supervision and enforcement authority may apply to activities related to auto lending, the Dodd-Frank Act explicitly limits the CFPB’s authority over motor vehicle dealers’ activities. CRS further explained that the CFPB’s enforcement efforts related to credit transaction anti-discrimination and credit reporting rights have recently proven relevant to the auto lending industry. The report highlighted that in August 2025, the CFPB issued an advance notice of proposed rulemaking to raise the origination threshold for larger nonbank participants (covered by InfoBytes here), and in November of the same year proposed a rule stating that the ECOA does not authorize disparate impact claims (covered here). The report concluded with policy considerations for Congress, including the impact of tariffs on car affordability, reduced fuel economy standards, and consumer protection issues such as fair lending, among others.