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Disclosure Requirements Car Dealerships

Fox Rothschild LLP

Federal Court Will Hear Auto Dealers Challenge to New FTC Regulations

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On Oct. 7, the 5th Circuit Court of Appeals will hear arguments in a case that could significantly reshape how auto dealerships operate. The National Automobile Dealers Association is arguing that the Federal Trade...more

Fox Rothschild LLP

Pennsylvania Auto Dealerships Should Prepare for Regulatory Changes

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Pennsylvania Auto Dealerships will need to follow several new regulations starting August 19, 2024. The regulations, developed by the Office of the Attorney General (OAG), require dealerships to disclose the following six...more

Hinch Newman LLP

1MM FTC Settlement With Online Used Car Dealer Over Alleged Misrepresentations and Failing to Deliver on Time

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On July 2, 2024 the Federal Trade Commission announced that it initiated action against online used car dealer Vroom for allegedly misrepresenting that it thoroughly examined all vehicles before listing them for sale and...more

Hudson Cook, LLP

FTC and Online Used Car Dealer Agree to Settle Alleged Unfair and Deceptive Advertising and Business Practices Claims

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On July 2, 2024, the FTC filed a joint motion for entry of the FTC and the Company's stipulated order for permanent injunction, monetary judgment, and other relief to resolve allegations of misleading consumers who purchased...more

Husch Blackwell LLP

FTC Finalizes—and Then Pauses—CARS Rule Impacting Dealers, Auto Finance Companies

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On December 12, 2023, the Federal Trade Commission (FTC) announced it has finalized the Combating Auto Retail Scams Rule (CARS Rule), which imposes various obligations affecting dealers’ sales practices and will also impact...more

Alston & Bird

FTC Finalizes CARS Rule Imposing Substantial Regulatory Requirements on Auto Dealerships

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The Federal Trade Commission (FTC) has finalized its Combating Auto Retail Scams Trade Regulation (CARS) Rule, which will affect almost every aspect of auto advertising and sales. Our Consumer Protection/FTC Team explains how...more

Ballard Spahr LLP

AFSA asks House Appropriations Committee to block proposed FTC Motor Vehicle Dealers Trade Regulation Rule

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On June 21, 2023, the American Financial Services Association (“AFSA”) asked the House Appropriations Committee to include language in the Financial Services and General Government appropriations bill that would prevent the...more

Ballard Spahr LLP

FTC declines to extend comment period for proposed motor vehicle dealer rule

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The FTC has declined requests to extend the comment period for its proposed rule that would impose a number of new substantive and disclosure requirements on motor vehicle dealers in connection with the car buying or leasing...more

Seyfarth Shaw LLP

FTC Begins Process To Adopt Rules For New Car Dealer Advertising And Sales

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On June 23, 2022, the Federal Trade Commission (FTC) announced that it has initiated the process to adopt regulations for dealers in connection with the advertising and sale of new cars. The proposed rules target “[d]ealer...more

Holland & Knight LLP

New Rules of the Road: FTC's Proposed Changes to Car, Boat, Motorcycle and RV Sales Practices

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The Federal Trade Commission (FTC) has issued a new proposed rule that aims to make the "motor vehicle"-buying process more clear and competitive, and also allow the FTC to recover money when consumers are misled or charged...more

Ballard Spahr LLP

FTC proposes new rule imposing prohibitions and disclosure requirements on auto-dealers in car-buying process

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The Federal Trade Commission (FTC) recently proposed a rule that would impose a number of new substantive and disclosure requirements on auto-dealers in the car-buying process. The FTC described the proposed Rule as one...more

Morgan Lewis

Proposed Trade Regulation Rule on Auto Dealer Sales Practices Could Dramatically Affect Auto Finance

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By a 4-1 vote on June 23, 2022, the US Federal Trade Commission (FTC) issued a notice of proposed rulemaking that is squarely aimed at changing the way dealers interact with customers in the automotive financing process, with...more

Hudson Cook, LLP

What You Say May Undo What You Do

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The retail installment sales contracts used by auto dealerships include disclosures related to GAP insurance and other debt cancellation products that are required under the federal Truth in Lending Act in order for the...more

Hudson Cook, LLP

Is Your Ad Clear and Conspicuous? Apparently it Depends.

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We’ve all heard the jokes about fine print before – the text is so small you could be agreeing to give the dealership your first-born child. However, for regulators the fine print is no laughing matter. The bottom line is...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

Hudson Cook, LLP

AFSA Extra Credit Podcast: Auto Remote Sales Compliance

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The Federal Trade Commission's Cooling-Off Rule has been around since 1972 (it became effective in 1974), but generally has been a non-issue for dealers until the Coronavirus pandemic when dealers were forced to conduct...more

Seyfarth Shaw LLP

Regulators Unveil Guidance On Best Practices for Internet Vehicle Sales

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Acknowledging that “[c]onsumers are clamoring for the opportunity to purchase the vehicles of their choice online because it expands the options available and enables them to save a considerable amount of time and possibly...more

ArentFox Schiff

CCPA’s Potential Impact in the Automotive Space

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While the California Consumer Privacy Act has impacted businesses in all sectors, one industry that has been steadily barreling toward compliance is the automotive industry. Simply put: The new “oil” in the automotive sector...more

Hudson Cook, LLP

Does Your Credit Application Need a Tune-Up?

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When a customer sits down at the finance desk in your dealership, the first step is to take some basic information about them. But, the credit application isn’t just about obtaining identifying information. Federal law...more

Ballard Spahr LLP

New York City adopts new requirements for used car dealers

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The New York City Department of Consumer Affairs (DCA) has adopted new rules for used car dealers, requiring all licensed dealers to make additional disclosures to consumers and creating a new consumer bill of rights for the...more

Ballard Spahr LLP

New York City proposes new disclosure requirements for used car dealers

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The New York City Department of Consumer Affairs (DCA) has proposed new rules for used car dealers that would require dealers to provide the following disclosures to buyers...more

Ballard Spahr LLP

FTC Consent Order Creates Uncertainty for Advertising of Credit, Lease Offers

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A recent Federal Trade Commission (FTC) consent order with two Ohio auto dealers creates uncertainty not only for auto dealers, but also for all other businesses advertising credit or lease offers. The order settled...more

Manatt, Phelps & Phillips, LLP

Regulators Keep Their Feet on the Gas in Actions Against Auto Lenders; NY AG Latest to Bring Suit

Why it matters - The automotive industry is continuing to face heavy scrutiny from regulators. On the heels of a Federal Trade Commission operation and new oversight from the Consumer Financial Protection Bureau, the...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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