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Unfair or Deceptive Trade Practices Consumer Financial Protection Bureau (CFPB) Car Dealerships

Troutman Pepper Locke

California Introduces Its Version of the CARS Act Signaling a New Wave of State Regulation for Auto Dealers

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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

Hinshaw & Culbertson - Consumer Financial...

FTC Finalizes Significantly Narrowed Junk Fees Rule – Initial Takeaways Applicable to the Auto Industry

On December 17, 2024, the Federal Trade Commission (FTC) issued its final trade regulation rule, "Rule on Unfair or Deceptive Fees," commonly referred to as the "Junk Fees Rule." We review the significance of the Final Rule...more

Ballard Spahr LLP

Fifth Circuit Court of Appeals Schedules Oral Arguments in CARS Rule Challenge for Oct 7

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The Fifth Circuit Court of Appeals has set oral arguments for Oct. 7 in the challenge of the Federal Trade Commission’s Combating Auto Retail Scams Rule (“CARS Rule”). The petition, filed on January 5, 2024 by the National...more

Ballard Spahr LLP

Auto dealer trade groups challenge FTC CARS Rule in Fifth Circuit

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On January 5, 2024, two trade groups representing auto dealers filed a petition for review challenging the Federal Trade Commission’s (“FTC”) new Combating Auto Retail Scams Rule (“CARS Rule”). In the petition, the National...more

Wiley Rein LLP

Wiley Consumer Protection Download (January 8, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Morgan Lewis

FTC’s Final ‘Cars Rule’ on Dealer Sales Practices: Implications for Banks, Auto Finance, and ‘captives’

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The Federal Trade Commission recently issued a final rule that is squarely aimed at changing the way dealers interact with customers in the financing process. The final rule takes effect on July 30, 2024....more

Wiley Rein LLP

Wiley Consumer Protection Download (December 18, 2023)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Brownstein Hyatt Farber Schreck

A Quiet Policymaking Power Grab

Federal agencies look to expand regulatory reach using sweeping UDAAP and UDAP authority - With active regulatory agendas at several federal agencies and what seems like back-to-back hearings considering legislative...more

Kelley Drye & Warren LLP

Update on Discrimination and Unfairness – The FTC’s Case Against Passport Automotive Group

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In late September, we blogged about a lawsuit that the Chamber of Commerce and other business groups filed against the CFPB, challenging the CFPB’s update to its Supervision and Examinations Manual. As updated, the manual now...more

Sheppard Mullin Richter & Hampton LLP

FTC Imposes Record-Setting $10M Fine Against Multistate Auto Dealer, Settling Charges of Racial Discrimination and Unauthorized...

On March 31, the FTC and Illinois State Attorney General announced a settlement of charges against a large, multistate auto dealer that allegedly discriminated against black consumers and included illegal junk fees for...more

Hudson Cook, LLP

Menu? We Don't Need No Stinkin' Menu. Yes, You Do!

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As you know, the pandemic shelter-at-home orders forced the closing of dealerships across the country. I suspect that the new ways dealerships have developed to continue to move the metal have inspired some dealerships to...more

Ballard Spahr LLP

FTC study examines issues experienced by consumers when buying and financing a vehicle

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Last week, the FTC released two new reports about the agency’s findings from an April 2017 study of consumers’ experiences with the car buying process. The FTC’s Bureau of Consumer Protection (BPC) authored a summary report...more

Hudson Cook, LLP

Actions Speak Louder than Words

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One of my all-time favorite sayings is “actions speaker louder than words.” Or, in other words, what you do has a stronger impact on people than what you say.  I can think of no better application of that maxim than to the...more

Hudson Cook, LLP

In Times of Peace, Prepare for War

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I just finished up a very active conference season. I’ve been on the “conference circuit” as some would say, since early January. Being on the conference circuit has enabled me to re-connect with friends, colleagues, clients...more

Hudson Cook, LLP

Compliance: Setting up a Preventative Maintenance Compliance Budget

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Prioritizing compliance with federal and state law may be the last item on your never ending to-do list. Most days, you have bigger fish to fry - you want to increase sales and decrease overhead. However, a small investment...more

White & Case LLP

Consumer financial services: The road ahead: Auto finance

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In 2018, the CFPB continued to pay attention to the auto finance industry, with a particular focus on indirect (dealer-arranged) auto lenders and unfair or abusive loan servicing practices....more

Bradley Arant Boult Cummings LLP

2017 in Review: Three State Enforcement Trends Impacting the Auto Finance Industry

Auto lenders, like many private citizens, began 2017 curious as to what change the impending Trump administration would bring. In the landscape of government enforcement, however, the consensus amongst industry participants...more

Bradley Arant Boult Cummings LLP

CFPB Issues Final Rules on Payday and Vehicle Title Loans—Little Impact for Auto Lenders

The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and...more

Ballard Spahr LLP

CFPB announces consent order with buy-here pay-here used car dealer

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The CFPB has announced that it has entered into a consent order with a Colorado buy-here pay-here used car dealer to settle charges that the dealer’s sales and advertising practices violated the Truth in Lending Act and the...more

Goodwin

Add-On Products Continue To Present Litigation Risks For Lenders

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The Consumer Financial Protection Bureau’s recent action against two credit card vendors regarding credit monitoring and identity theft protection services is a reminder of the legal risks associated with certain add-on...more

Ballard Spahr LLP

New York Announces Settlements with Six Auto Dealers

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Last week, New York Attorney General Eric Schneiderman announced settlements with six auto dealers imposing fines ranging from $7,500 to $15,000 for allegedly engaging in deceptive and misleading advertising practices. The...more

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