Report on the Racial Impact of AHFC's Finance Charge Markup Policy

This report has been prepared in the matter of Terry Willis, et al. v. American Honda Finance Corporation (“AHFC”). I have been asked by plaintiffs’ counsel to review the data on auto finance customers that has been provided by AHFC (and that has been race-coded by CLC Compliance Technologies, Inc.) in this litigation to determine whether or not there is evidence of a disparate impact on African-Americans who finance their cars through AHFC because they pay a higher subjective markup than similarly situated White customers. The subjective markup I have estimated in this case is based on the difference between the credit risk-based “buy rate” and the ultimate annual percentage rate (“APR”) paid by the borrower.
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