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Unfair or Deceptive Trade Practices Federal Trade Commission (FTC) CARS Rule

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

Mayer Brown

A Post-CARS Rule Brake? Not So Fast. Buckle Up for New Regulatory Activity in the Motor Vehicle Space

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The Fifth Circuit vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, determining that the FTC failed to follow its own procedural requirements...more

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

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

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In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Orrick, Herrington & Sutcliffe LLP

5th Circuit strikes down FTC’s CARS Rule

On February 4, the U.S. Court of Appeals for the Fifth Circuit struck down the FTC’s Combating Auto Retail Scams Trade Regulation Rule (CARS Rule), which aimed to address deceptive practices such as bait-and-switch tactics...more

BakerHostetler

5th Circuit Slams the Brakes on FTC’s CARS Rule

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There are generally two paths that the Federal Trade Commission (FTC) takes for rulemaking. First, there may be a specific statute that gives the FTC specific rulemaking authority, such as the Children’s Online Privacy...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

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – February 2025

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....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

Venable LLP

The Fifth Circuit Slams the Brakes and Vacates FTC CARS Rule

Venable LLP on

This week, the U.S. Court of Appeals for the Fifth Circuit vacated the Federal Trade Commission’s (FTC) Combatting Auto Retail Scams (CARS) rule....more

Seyfarth Shaw LLP

5th Circuit Vacates FTC New Car Dealer Rule

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On January 27, 2025, the Fifth Circuit handed new car dealers a significant win by invalidating the Combating Auto Retail Scams (CARS) Trade Regulation Rule issued by the Federal Trade Commission (FTC) in December 2023. In a...more

Fox Rothschild LLP

In Victory for Auto Dealers, Federal Court Strikes Down FTC’s CARS Rule

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Auto dealers nationwide received good news Monday when the Fifth Circuit Court of Appeals struck down the CARS Rule, a set of regulations passed by the Federal Trade Commission (FTC) that would have imposed cumbersome...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

FTC Posts $20 Million Settlement With Dealer Group For Alleged Deceptive Practices - Seyfarth's Future of Automotive Series

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On Thursday, December 19, 2024, the Federal Trade Commission (FTC) and Illinois Attorney General announced a massive $20 million settlement with Leader Automotive Group, the operator of 10 dealerships in and around...more

Troutman Pepper Locke

FTC and Illinois AG Secure $20M Settlement with Leader Automotive Group Over Allegedly Deceptive Practices

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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

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

Seyfarth Shaw LLP

Trump Presidency Promises Turbulence for the Auto Industry

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President-elect Donald Trump’s return to the White House is set to bring significant changes to the auto industry. The Biden era’s focus on rapid electrification, global trade, and an active FTC will be replaced by an...more

Seyfarth Shaw LLP

NADA Faces Skeptical Fifth Circuit Panel On Challenge To FTC New Car Dealer Rule - Seyfarth's Future of Automotive Series

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On October 9, 2024, the Fifth Circuit heard oral argument on the administrative challenge lodged by the National Automobile Dealers Association (NADA), a national trade association representing the interests of U.S. car...more

Troutman Pepper Locke

Investigation Tag Team: The FTC and the State of Arizona — Moving the Metal: The Auto Finance Podcast

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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

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

Ballard Spahr LLP

FTC, State of Arizona Charge Auto Dealership with Deceiving Consumers

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On August 15, 2024, the Federal Trade Commission (“FTC”) and Arizona Attorney General announced a proposed settlement with an Arizona-based vehicle dealership to resolve allegations that the dealership misrepresented prices...more

Seyfarth Shaw LLP

FTC Continues Aggressive Enforcement Actions To Deter Deceptive Pricing Practices By Car Dealers - Seyfarth's Future of Automotive...

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On Thursday, August 15, 2024, the Federal Trade Commission (FTC) and Arizona Attorney General announced a $2.6 million settlement to resolve claims that Coulter Motor Company used deceptive online advertising to lure...more

Troutman Pepper Locke

FTC and Arizona AG Reach $2.6 Million Settlement with Motor Vehicle Dealer Over Alleged Deceptive and Discriminatory Sales and...

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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

Ballard Spahr LLP

Vehicle Services Company CarShield Settles Complaint with FTC

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CarShield, a company that sells vehicle service contracts (VSCs), will pay $10 million to settle FTC allegations that its advertisements and telemarketing pitches deceived consumers, the agency announced on July 31....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

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