外文翻译---汽车业竞争的关键：汽车金融中自由市场和消费者的保护-汽车设计(编辑修改稿)

外文翻译---汽车业竞争的关键：汽车金融中自由市场和消费者的保护-汽车设计(编辑修改稿)内容摘要：

ending, and a greater ponent of industry profitability. But unlike in mortgage, the auto finance industry did not particularly expand its level of subprime borrowing during the course of the bubble. The fraction of overall lending attributable to subprime remained roughly constant: approximately 20% of loans to borrowers below FICO 660. This is an intuitive result: for lowerine Americans, in most parts of the country, car ownership is often a practical requirement to mute to and from work. Unlike subprime homeownership, subprime car ownership was not a onetime luxury transformed into an attainable “necessity” by the availability of easy credit. Rather, subprime car ownership has actually been a necessity, not a luxury, all along. Other underwriting criteria, however, did slip including loantovalue ratios and, especially, the length of loan terms. (See Figure 6). Cars, of course, depreciate quickly over time. Because older cars are worth a good deal less than newer cars, when a borrower defaults near the end of a long loan term, the resale value of the repossessed vehicle is typically significantly less than the unpaid principal balance owed. Lower recoveries on repossessed cars, in turn, mean worse loss severities, and, therefore, higher credit losses. Beyond the credit deterioration of existing portfolios, the bubbleera’s widespread availability of permissive LTVs and loan terms had a second, more subtle, and potentially more corrosive effect. By temporarily boosting auto dealers’ sales volume, and especially their lending profitability, the credit bubble may well have forestalled actual structural change within the auto dealer sector. At first glance, it would appear that, for years, auto dealers were able to defy free market gravity. The industry suffered a 200basis point decline in new car gross margins over the past 10 years. This would seem crippling, given that selling cars is a brutally thinmargin business, and dealerships tend to run only 150basis point pretax profit margins, even in good times. And yet, somehow, dealerships remained remarkably profitable running profits at 2025% of worth throughout their industry’s topline collapse. Dealerships even turned a profit during the otherwise calamitous 2020. (See Figure 7). The explanation for this otherworldly performance is actually quite simple: As gross margins in the auto sales business deteriorated over the past decade, auto dealers managed to dramatically increase their sales of highmargin consumer loans, service contracts, and other profitable ancillary services. (See Figure 8). By the end of the credit bubble, in other words, the financial viability of American auto dealers had bee critically dependent on serving as a financial middleman, marking up loans between moneylosing captive finance panies on the one hand, and their increasingly cash strapped and wary customers on the other. Over the course of the bubble, auto dealerships employers of more than 1 million Americans had managed to steer themselves into a strategic and financial dead end. Evaluating the CFPA Exemption for Auto Dealers It is within that industry context that the House Financial Services Committee voted to exclude auto dealers from the CFPA’s rulemaking and enforcement scope. And it is within that industry context that the wisdom of the exemption should be gauged. Notably, evaluating the wisdom of the dealer exemption (or any other exemption, for that matter) need not first determine whether the CFPA itself is a good or bad idea. Because it is an exemption being evaluated, the creation of the CFPA is an assumption of the analysis. And given the lengthy substantive debate among policymakers regarding the CFPA, the logical premises that underpin the assumed creation of the agency are clear. There are three such premises. The CFPA will be enacted if, and only if, Congress decides that: (1) consumer protection is a materially important objective in financial services。 (2) prehensive rulemaking is superior to rules based on chartertype or other formal distinctions。 and (3) centralized supervision and enforcement of consumer protection is better than a more decentralized approach tied to prudential regulation. (See Figure 9). If there is a CFPA, then, the only exemptions from the CFPA’s authority should be in those cases where the premises that justify the agency’s creation do not apply. Because auto dealers do not have prudential regulators (like banks), the third stage of the framework is not relevant. Applying the first two prongs, though, makes clear that the exemption is profoundly wrongminded. Importance of consumer protection in the dealer channel Given the industry structure detailed above, consumer protection seems a critical regulatory concern with respect to auto dealers. Role of dealers Auto dealers are the dominant distribution channel in auto finance, and auto finance is the largest category of consumer credit outside of mortgage. Far from being passive administrators with respect to auto finance, auto dealers actively market and price borrowers’ loans. Moreover, the dealers’。