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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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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.

Yesterday, California Governor Gavin Newsom announced the appointment of Rohit Chopra, former Director of the Consumer Financial Protection Bureau (CFPB) and former Federal Trade Commission (FTC) Commissioner, as Secretary of the state’s new Business and Consumer Services Agency (BCSA). The new cabinet‑level agency, which formally launches on July 1, 2026, is designed to consolidate and elevate state‑level consumer and market oversight at a moment when federal enforcement is being scaled back. Governor Newsom framed the move as bringing “one of the nation’s most prominent consumer protection leaders” into state government to crack down on corporate abuse, curb junk fees, and lower costs for Californians.

On May 6, several Senate Democrats sent letters to three nationwide consumer reporting agencies (CRAs) requesting detailed information about how Buy Now, Pay Later (BNPL) loans are being handled in consumer reporting. The letters, led by Senator Elizabeth Warren (D‑MA), follow a prior set of information requests made in November 2025 to BNPL providers about whether and how they furnish BNPL data to CRAs.

On May 5, the U.S. Court of Appeals for the Second Circuit issued its long‑awaited decision on remand in Cantero, again holding that New York’s 2% interest‑on‑escrow statute (General Obligations Law § 5‑601) is preempted as applied to national banks. This follows the U.S. Supreme Court’s unanimous 2024 opinion (discussed here), which vacated the Second Circuit’s earlier decision and instructed the court to apply the Barnett Bank “prevents or significantly interferes” standard through a “nuanced comparative analysis” of prior preemption precedents.

On April 30, the Federal Communications Commission (FCC or Commission) released a Further Notice of Proposed Rulemaking (FNPRM) that would significantly tighten “Know-Your-Customer” (KYC) obligations for originating voice service providers. The Advanced Methods to Target and Eliminate Unlawful Robocalls (CG Docket No. 17‑59) is the latest step in the Commission’s effort to attack illegal calls “at every point in their lifecycle.”

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a major FTC–Maryland AG settlement with multiple auto dealerships over alleged deceptive pricing, unauthorized add-ons, and misleading financing practices. Brooke and Chris walk through the redress and penalty structure and explain how “total price,” clear disclosure, and express informed consent are being enforced post-CARS Rule. They also discuss what dealers and auto finance companies should do now to strengthen compliance, documentation, and oversight of dealer practices.

In this second installment of Moving the Metal: The Auto Finance Podcast’s 2025 auto finance year in review, hosts Brooke Conkle and Chris Capurso unpack three emerging risk hotspots: service member auto lending, changes to Consumer Financial Protection Bureau (CFPB) larger-participant supervision, and state vehicle data privacy laws. They break down the CFPB’s 2025 Servicemember Auto Lending Report, proposed shifts to the auto larger-participant threshold, and New Jersey’s first-of-its-kind vehicle data deletion law — along with what each development means for compliance programs, dealer oversight, and litigation risk. Tune in to hear how federal and state trends are reshaping auto finance risk and what companies should be doing now to stay ahead in 2026.

On April 3, Kentucky enacted SB 158, a comprehensive statute governing products that offer benefits in connection with personal property, with a particular focus on add‑on products sold with vehicle finance and lease transactions. The law creates a formal regulatory framework for “vehicle financial protection products,” provides that they are not “insurance”, and ties compliance to the state’s retail installment and consumer loan regimes. Most vehicle financial protection provisions apply to products that become effective on or after January 1, 2027.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down two major developments turning up regulatory pressure on the auto finance industry. They unpack the FTC’s “WARNING LETTER” campaign targeting nearly 100 dealers, focused on UDAAP risks in pricing and advertising, including hidden fees, conditional pricing, mandatory add-ons, and unavailable vehicles. They also examine Senator Elizabeth Warren’s sweeping, short-fuse request for granular data comparing servicemember and civilian auto finance outcomes, signaling heightened bipartisan scrutiny of military borrowers. Tune in to hear what these letters really mean, what regulators are looking for, and how auto finance companies and dealers should be preparing now.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso kick off a two-part Auto Finance Year in Review by unpacking the Fifth Circuit’s vacatur of the FTC CARS Rule, the decision by the Trump 2.0 administration not to appeal, and how states — led by California’s CARS Act and Oregon’s new auto finance law — are quickly filling the gap with their own disclosure, add-on, cancellation, and recordkeeping requirements, creating a growing state-by-state patchwork that challenges truly uniform national compliance programs for dealers, finance companies, and servicers.