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Chris Capurso

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Chris focuses his practice on consumer financial services compliance, guiding clients through the many federal and state laws and regulations that impact consumer credit programs.

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In this mid-year roundup episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso recap the biggest developments shaping the auto finance industry in the first half of 2026, including the FTC’s widely unexpected “Notorious 97” warning letters to nearly 100 dealers, a wave of state-level UDAP enforcement actions, Senator Elizabeth Warren’s data requests targeting repossession and service member lending practices, Kentucky’s new legislative framework for GAP and vehicle financial protection products, a significant New Jersey dealer enforcement action under the state’s Consumer Fraud Act, and the growing compliance risks around fraud detection and AI use in the sales and financing process — wrapping up with a look ahead at what the second half of the year may bring.

On July 1, the Federal Trade Commission (FTC) published a proposed policy statement addressing whether AI companies that steer their systems’ outputs toward undisclosed ideological objectives, rather than toward the objectives that consumers request or reasonably expect, may be engaging in deceptive acts or practices in violation of § 5 of the FTC Act. The public comment period closes July 31, 2026.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down two significant state-level regulatory responses to the Federal Trade Commission’s (FTC) March 2026 wave of 97 warning letters targeting auto dealers — examining how Louisiana’s Motor Vehicle Commission is formally updating its advertising regulations to align with FTC guidance on total price transparency, and how the Massachusetts Attorney General’s Office issued a sweeping advisory putting dealers on notice that hidden documentation fees violate state law, with potential double exposure under both motor vehicle dealer regulations and the Massachusetts UDAP statute.

Louisiana and Massachusetts have each recently issued guidance addressing motor vehicle dealer advertising practices, particularly around the disclosure of fees in advertised vehicle prices. Both actions follow the Federal Trade Commission’s March 13, 2026 “Notorious 97” warning letters to auto dealership groups nationwide (discussed here) and reflect ongoing efforts at the state and federal level to ensure that advertised prices accurately reflect the total cost consumers will be required to pay.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a New Jersey enforcement action against a dealer group that began with a 2018 consent order and escalated into a 2023 complaint packed with Consumer Fraud Act allegations — from gray market disclosures and duplicative add-ons to odometer violations and improper warranty sales. The trial court initially imposed over $10 million in penalties before two rounds of reconsideration brought the final figure down to $155,000, offering a striking look at how courts balance deterrence, proportionality, and ability to pay. Tune in for a practical breakdown of what this case means for dealers navigating compliance in an era where state enforcement is quickly becoming the front line.

Last month, the New York City Department of Consumer and Worker Protection (DCWP) announced a significant enforcement action against 2541 E Tremont Ave Auto, LLC, which operated as “Honda of the Bronx.” DCWP alleged that the Bronx-based used auto dealer engaged in a pattern of deceptive practices, including bait‑and‑switch pricing, hidden financing costs, and “cancellation traps,” in violation of New York City’s consumer protection laws. The dealership admitted wrongdoing and agreed to pay a total of $129,999, consisting of $61,499 in civil penalties and $68,500 in restitution to affected consumers.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by partner Brian Casey to unpack Kentucky SB 158, a new law creating a comprehensive framework for vehicle financial protection products, including GAP waivers, excess wear and tear waivers, and vehicle value protection agreements. They explain how SB 158 designates these products as “not insurance,” imposes clear optionality and disclosure requirements, mandates a 30-day free look period, and addresses how benefits and refunds work — particularly in repossession scenarios. They also discuss what dealers, lenders, and administrators should do now to update forms, contracts, and processes, and how Kentucky’s approach may become a model for other states considering regulation of auto add-on products.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso examine the evolving fraud threats facing auto dealers and finance companies, from income and identity fraud to vehicle-related scams like forged VINs and deceptive trade-ins. They explore how these schemes translate into chargebacks, consumer lawsuits, and regulatory scrutiny; the tension between robust fraud controls and sales friction; and why clear policies, consistent verification, strong dealer-lender agreements, and meticulous documentation are critical both to preventing fraud and defending disputes when something slips through.

On May 13, the Federal Trade Commission (FTC) filed and simultaneously settled a lawsuit against online digital photo and video platform Shutterstock, Inc. in the Southern District of New York, alleging that the company used deceptive “negative option” subscription practices in violation of § 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA). According to the complaint, Shutterstock misled consumers about its “annual, paid monthly” (APM) plans and on‑demand “packs,” failed to clearly disclose automatic renewals and hefty early‑termination fees, converted “free trials” into paid annual plans without adequate notice, and made it difficult and time‑consuming for customers to cancel.

Marking the latest development in the trend toward increased regulation of automatically renewing subscription offers, on April 8, the New York City Department of Consumer and Worker Protection (DCWP) proposed what would be the nation’s first municipal “Click to Cancel” rule. This proposed regulation would mirror existing state law requirements providing for consumer rights and protections concerning automatic renewal or continuous service offers. In doing so, the DCWP takes aim at so-called “subscription traps” that it claims unfairly prevent consumers from discontinuing services they no longer wish to pay for. Specifically, the rule would make failure to offer consumers streamlined cancellation methods for continuous service offers a deceptive and unconscionable practice in violation of the New York City Administrative Code. This proposal marks the latest development in New York City’s efforts to prioritize consumer protection initiatives across economic sectors. Important elements of the proposed rule are summarized below.