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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 episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso welcome back Chris Carlson to examine recent state attorney general enforcement actions against auto dealers in New York and Alaska. They discuss scrutiny of sales commissions, optional add-on products, and undisclosed documentary fees, highlighting the importance of clear pricing and consumer disclosures. The conversation also explores restitution considerations, coordination between state AGs and the FTC, and emerging enforcement concerns involving algorithmic pricing and consumer data.

On October 8, the Federal Trade Commission (FTC) filed a complaint and simultaneous stipulated order against a network of more than 35 dealerships in central Florida, the first such action against a dealership group in direct response to the FTC’s March 2026 warning letters (discussed here).

On October 9, Michigan Governor Gretchen Whitmer signed Senate Bill 198 into law as Act No. 113 of the Public Acts of 2026, enacting the Motor Vehicle Dealer Data Collection Act. The law took effect immediately upon signing and establishes a comprehensive framework governing how manufacturers, third parties, dealer data vendors, and authorized integrators may access, share, and use data generated or stored within a dealer’s systems.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down the FTC’s newly released 14-question FAQ guide on auto price advertising transparency, the follow-up to the agency’s “notorious 97” warning letters. They walk through what must be included in an advertised price (and what can be excluded); how document fees and state law requirements interact with FTC rules; the treatment of MSRP, discounts, and leasing processing fees; rules on advertising in-transit vehicles and using representative photos; and the thorny question of who bears responsibility for inaccurate pricing across dealers, third-party advertisers, and OEMs. They close with the FTC’s stance on compliance timing and its reliance on consumer and competitor complaints to enforce a level playing field.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a recent DOJ/U.S. Attorney’s Office settlement with a lease-here, pay-here dealership over violations of the Servicemembers Civil Relief Act (SCRA). They discuss the two provisions at the heart of the case, repossession protections and lease termination rights, and the way a dealer’s failure to check military status and refund lease payments led to a $137,348 penalty and a robust, DOJ-approved compliance overhaul. Brooke and Chris explain why SCRA enforcement remains a bipartisan, well-funded priority (nearly $500 million recovered since 2011) and offer practical steps dealers and auto finance companies should take now, including mandatory DMDC database searches, documented military-orders intake procedures, thorough recordkeeping, and designated, trained SCRA points of contact. Tune in for a real-world roadmap of what regulators expect dealership compliance programs to look like.

This blog post was republished in insideARM on October 20, 2026.

On September 16, the New York Attorney General’s Office (OAG) announced a settlement with two Westchester County dealerships, resolving allegations of deceptive fee practices under General Business Law § 349 and § 350 and Executive Law § 63(12). The resolution requires more than $1 million in immediate consumer restitution, with additional claims-based payments potentially reaching into the millions, plus $700,000 in penalties. For dealers and finance professionals, the underlying findings are worth attention; the settlement is an illustration of how regulators are analyzing fee disclosure and add-on sales in current enforcement actions.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a recent $4 million settlement between the FTC and the Connecticut Attorney General’s Office against an auto dealership accused of deceptive pricing, unauthorized add-on charges, and phantom vehicle certifications. They discuss the significance of naming individual owners and managers as defendants, the growing coordination between federal and state regulators using UDAP authority to enforce what amounts to the “ghost” of the vacated FTC CARS Rule, and why junk fees, price transparency, and express informed consent remain top enforcement priorities regardless of administration. The hosts close with practical takeaways for dealers and finance companies on aligning advertising, add-on sales practices, and compliance monitoring to avoid similar exposure, including private litigation risk under state consumer protection statutes and the Holder Rule.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down California’s CARS Act, set to take effect October 1. They trace the law’s roots back to the FTC’s now-overturned CARS Rule, walk through its four core compliance pillars (misrepresentations, total price disclosures, valueless add-ons, and recordkeeping), and dig into the new three-day right to cancel for used vehicles. The hosts also cover enforcement risk under California’s UCL and CLRA, the exposure lenders face through the Holder Rule, and five practical steps dealers and their partners should be taking right now to get ahead of the law’s arrival.