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Automotive Industry › Car Dealerships › Rulemaking Process

Troutman Pepper Locke

Update on FTC’s CARS Rule

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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

Holland & Knight LLP

Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule: Key Implications for Dealers

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The U.S. Court of Appeals for the Fifth Circuit on Jan. 27, 2025, vacated the Federal Trade Commission's (FTC) Rule on Combating Auto Retail Scams (CARS Rule) before it could take effect, finding that the FTC failed to follow...more

Ballard Spahr LLP

Fifth Circuit Court of Appeals strikes down FTC CARS Rule

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The Fifth Circuit Court of Appeals has struck down the FTC’s controversial CARS Rule, saying that the commission violated its own procedural rules by failing to issue an Advance Notice of Proposed Rulemaking (“ANPRM”) before...more

Troutman Pepper Locke

Fifth Circuit Vacates FTC’s CARS Rule

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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

Seyfarth Shaw LLP

Fifth Circuit Set to Weigh Challenge to FTC’s CARS Rule - Seyfarth's Future of Automotive Series

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The administrative challenge brought by the National Automobile Dealers Association (NADA) and another trade association against the Combating Auto Retail Scams (“CARS”) Trade Regulation Rule, issued last year by the Federal...more

Sheppard Mullin Richter & Hampton LLP

FTC Targets Junk Fees, Bait-and-Switch Advertising by Auto Dealers

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On June 23, the FTC proposed a rule that would prohibit junk fees, bait-and-switch advertising, and other deceptive practices by auto dealers to protect consumers and honest dealers in the car-buying process...more

Venable LLP

FTC Starts the Engine on Car Sales Fees and Advertising Rulemaking, but Other Rulemaking Faces Major Questions

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The FTC is off to the races with another proposed rulemaking. On June 23, the FTC, by a 4-1 vote, issued a notice of proposed rulemaking (NPR) to combat what it perceives as “junk fees” and “bait-and-switch advertising...more

Ballard Spahr LLP

FTC Follows in CFPB Footsteps with GLBA Privacy Notices

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The Federal Trade Commission (FTC) recently proposed amendments to its Gramm-Leach-Bliley Act (GLBA) rules requiring motor vehicle dealers to send their customers an annual privacy notice. The amendments would allow motor...more

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