As of April 27, 2025, the Federal Trade Commission (FTC) had not filed a petition for a writ of certiorari to appeal the Fifth Circuit’s decision vacating the Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The...more
5/6/2025
/ Administrative Procedure Act ,
Appeals ,
Automotive Industry ,
Car Dealerships ,
CARS Rule ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Motor Vehicles ,
Regulatory Agenda ,
Regulatory Reform ,
Rulemaking Process ,
Scams ,
Statute of Limitations ,
Unfair or Deceptive Trade Practices ,
Vacated
This episode of Regulatory Oversight spotlights recent Moving the Metal episode "The Future of Auto Dealership Compliance: A Conversation With Tom Kline." In this episode, Brooke Conkle and Chris Capurso from Troutman Pepper...more
In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso from Troutman Pepper Locke's Consumer Financial Services Practice Group discuss the rise and fall of the Junk Fee Rule and the CARS Rule. They delve...more
In a move that could significantly impact the auto retail industry, California has introduced Senate Bill 766, known as the California Combating Auto Retail Scams (CARS) Act. Introduced by Senator Benjamin Allen (D) on...more
2/28/2025
/ Automotive Industry ,
California ,
Car Dealerships ,
CARS Rule ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Federal Trade Commission (FTC) ,
Motor Vehicles ,
Proposed Legislation ,
Recordkeeping Requirements ,
Regulation ,
Regulatory Requirements ,
Unfair or Deceptive Trade Practices
In this episode of Moving the Metal, Brooke Conkle and Chris Capurso from Troutman Pepper Locke's Consumer Financial Services Practice Group are joined by Tom Kline, lead consultant and founder of Better Vantage Point. Tom...more
Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in...more
1/28/2025
/ Administrative Procedure Act ,
Advanced Notice of Proposed Rulemaking (ANPRM) ,
Appeals ,
Arbitrary and Capricious ,
Automotive Industry ,
Car Dealerships ,
CARS Rule ,
Federal Trade Commission (FTC) ,
Final Rules ,
FTC Act ,
Motor Vehicles ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Interpretation ,
Unfair or Deceptive Trade Practices ,
Vacated
In this special year-in-review episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso from Troutman Pepper Locke's Consumer Financial Services Practice Group delve into the significant...more
In a significant enforcement action, the Federal Trade Commission (FTC) and the Illinois Attorney General have reached a $20 million settlement with Leader Automotive Group and its Canadian parent company, AutoCanada, over...more
12/23/2024
/ Car Dealerships ,
CARS Rule ,
Consumer Fraud ,
Enforcement Actions ,
False Advertising ,
Federal Trade Commission (FTC) ,
FTC Act ,
Online Reviews ,
Section 5 ,
Settlement ,
Statutory Violations ,
Unfair or Deceptive Trade Practices ,
Used Car Rule
In this podcast episode, Brooke Conkle and Chris Capurso are joined by esteemed senior practitioner Alan Wingfield to discuss the National Automobile Dealer Association’s (NADA) challenge to the Federal Trade Commission’s...more
In this episode, Chris Carlson, an associate in the Regulatory, Investigations, Strategy and Enforcement (RISE) practice, joins Brooke and Chris to discuss how federal and state regulators are collaborating on consumer...more
In this episode of the Moving the Metal podcast, hosts Brooke Conkle and Chris Capurso delve into the Federal Trade Commission's (FTC) recent report to the Consumer Financial Protection Bureau (CFPB). This report responds to...more
Last week, the Federal Trade Commission (FTC) and the State of Arizona announced a joint action against Coulter Motor Company, an Arizona-based motor vehicle dealership, and its former general manager, for allegedly engaging...more
8/19/2024
/ Automotive Industry ,
Automotive Loans ,
Car Dealerships ,
CARS Rule ,
Consumer Fraud ,
ECOA ,
Fair Lending ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FTC Act ,
Motor Vehicles ,
Race Discrimination ,
State Attorneys General ,
Unfair or Deceptive Trade Practices
In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC's proposed CARS Rule. After a refresher on the rule's requirements, Brooke and...more
On May 28, the Federal Trade Commission (FTC) released its annual report to the Consumer Financial Protection Bureau (CFPB) detailing enforcement and educational activities undertaken in 2023. The report pertains to actions...more
6/14/2024
/ Annual Reports ,
Automotive Loans ,
CARS Rule ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Leasing Act (CLA) ,
Electronic Fund Transfer Act ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Truth in Lending Act (TILA)
The Federal Trade Commission (FTC) and Connecticut Attorney General William Tong filed suit against auto dealer Manchester City Nissan (Manchester City), its owner, and several employees for allegedly deceiving consumers...more
1/11/2024
/ Car Dealerships ,
Cars ,
CARS Rule ,
False Advertising ,
Federal Trade Commission (FTC) ,
Fees ,
Financial Services Industry ,
FTC Act ,
Motor Vehicles ,
State Attorneys General ,
Unfair or Deceptive Trade Practices