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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 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.

On March 13, the Federal Trade Commission (FTC) announced that it is sending warning letters to 97 auto dealership groups across the country, signaling a renewed focus on deceptive pricing practices in the retail auto sector. The letters stress that advertised prices must reflect the total price consumers will be required to pay, including all mandatory, dealer-imposed fees other than government charges like taxes. The agency frames this effort as part of a broader initiative to promote price transparency across sectors such as rental housing, ticketing and hotels, grocery delivery, and now auto sales and leasing.

On March 11, the Federal Trade Commission (FTC) issued a new Advance Notice of Proposed Rulemaking (ANPRM) to revisit its Rule Concerning the Use of Prenotification Negative Option Plans. The move follows the Eighth Circuit’s 2025 decision vacating the FTC’s 2024 amendments (discussed here), which would have imposed uniform requirements on subscriptions, auto‑renewals, and trial‑to‑pay offers across all marketing channels. The ANPRM makes clear that while the FTC acknowledges that so-called negative options are widely offered and can provide benefits to both sellers and consumers, the FTC intends to address recurring billing and cancellation frictions that continue to generate a high volume of consumer complaints.

Colorado lawmakers are considering legislation that would significantly expand consumer protections around motor vehicle finance and sales. House Bill 26‑1261, introduced on February 19, 2026 and currently pending before the House Business Affairs & Labor Committee, would overhaul repossession timelines for certain “qualified motor vehicles,” restrict use of vehicle-disabling technology, and create a three‑business‑day right to return certain vehicles purchased from dealers.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by New York-based colleagues Bill Foley and Joe DeFazio to unpack the newly enacted New York FAIR Act (Fostering Affordability and Integrity through Reasonable Business Practices Act). They explain how the law fundamentally expands New York’s unfair, deceptive, or abusive acts or practices regime (from “deceptive” to now “unfair” and “abusive” practices) broadens coverage to small businesses and nonprofits, and gives the attorney general extraterritorial enforcement tools. The discussion focuses on how auto dealers and finance companies are already being singled out by New York officials, the litigation and enforcement risks this creates, and practical compliance steps — especially around add-on products, sales practices, underwriting, and emerging technologies such as AI.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso unpack Senator Elizabeth Warren’s February 5 data request to major auto finance companies, buy-here-pay-here dealers, and key industry trade groups about auto repossessions. They walk through the main categories of information sought — repossession activity and errors, consumer complaints and disputes, policies and training, vendor contracts, and handling of personal property — and discuss the tight 11-day response deadline and lack of a clear statutory hook for the request. Brooke and Chris also consider what this move may signal about future regulatory and enforcement activity in the auto finance space.

In 2025, the U.S. digital asset landscape evolved more dramatically than in any year since the industry’s inception. A pro‑innovation White House, an active Congress, and key regulators — including the U.S. Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Office of the Comptroller of the Currency (OCC), the Department of…