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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 dive into the latest Experian auto finance quarterly report to explore the latest trends in auto finance for the second quarter of 2025. They discuss key findings, including the rise in new and used vehicle financing, shifts in market share among banks, captives, and credit unions, and the surprising increase in loan amounts and monthly payments. The conversation also covers the growing trend of refinancing and its implications for the auto finance industry. Tune in to understand how these trends impact dealers and finance companies, and what they mean for the future of auto finance.

In this episode of Moving the Metal: The Auto Finance Podcast, Brooke Conkle and Chris Capurso delve into recent legislative changes affecting the auto finance industry in Connecticut and Oregon. They discuss Connecticut’s Senate Bill 1357, which introduces updates on automatic renewal provisions, dealer advertising requirements, and express warranties. The conversation highlights the compliance challenges these changes pose for dealers and finance companies. The hosts also explore Oregon’s House Bill 3178, focusing on new disclosure requirements, the reduced timeline for finalizing financing, and the right to void contracts. This episode provides a comprehensive analysis of how these state laws impact operations and potential litigation risks for industry professionals.

On October 6, Governor Gavin Newsom signed into law the California Combating Auto Retail Scams (CARS) Act. This legislation aims to fortify consumer protections and enhance transparency in the car-buying process. The enactment of this law follows a series of discussions and amendments, as highlighted in our previous blog and podcast, which traced the bill’s evolution and its alignment with the Federal Trade Commission’s (FTC) vacated CARS Rule.

On September 15, Oregon Governor Tina Kotek signed into law House Bill 3178, introducing new requirements for auto dealers in the state. This legislation aims to standardize certain aspects of auto finance transactions, specifically those involving retail installment contracts (RICs) or lease agreements, and ensure clarity in the car-buying process. The law will take effect in 2026.

In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group are joined by Chris Willis to explore the Consumer Financial Protection Bureau’s (CFPB) proposed changes to the larger participant rule for auto finance. The discussion delves into the CFPB’s current regulatory activities, including its focus on revisiting and potentially reducing the number of nonbank companies subject to supervision. The team examines the implications of raising the threshold for what constitutes a larger participant in the auto finance market and how this could impact industry dynamics. They also consider the broader regulatory landscape and the potential for future changes under different administrations. Tune in for valuable insights into the evolving world of auto finance regulation and what it means for industry participants.

In this episode of Moving the Metal: The Auto Finance Podcast, Brooke Conkle and Chris Capurso discuss California SB 766, known as the California CARS Rule. They explore the bill’s amendments, including changes to cancellation periods and record retention requirements, and analyze its implications for compliance and litigation in the auto finance industry. The conversation highlights the potential impact of state-level regulation and the possibility of similar legislation in other states. Tune in for insights into how these developments could shape the future of auto finance.

On August 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published a series of proposed rules aimed at redefining what constitutes a “larger participant” in several key financial markets. Under § 1024 of the Consumer Financial Protection Act, the Bureau’s supervisory authority extends to “larger participants” offering consumer financial products or services. The proposed rules seek to amend existing thresholds in the consumer reporting, auto financing, consumer debt collection, and international money transfer markets to better align with current market conditions and regulatory priorities. The Bureau is accepting comments on these proposals until September 22, 2025.

On July 28, the New Jersey Division of Consumer Affairs issued a reminder to more than 3,000 auto dealerships regarding their obligations under the New Jersey data deletion law, N.J.S.A. § 56:12-18.1. This law, enacted and effective in January 2024, requires dealerships to offer data deletion services for consumer information stored in vehicles accepted for resale or lease. Dealerships are now on notice of their compliance obligations under the law.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by Brian Casey, a partner in Troutman Pepper Locke’s Insurance, Transactional, and Regulatory Practice Group. Together, they explore the complex world of vehicle service contracts (VSCs) and ancillary products within the auto finance industry. Brian shares insights into the history and evolution of VSCs, discussing the distinction between insurance and non-insurance products and the regulatory landscape that governs them. The conversation delves into state-specific regulations, licensing requirements, and the impact of privacy laws like the Gramm-Leach-Bliley Act on the industry. Tune in to understand the intricacies of vehicle service contracts and the challenges faced by providers in navigating this dynamic regulatory environment.

An initiative designed to add significant regulatory obligations to the home improvement and solar financing industries is progressing through the California legislature. Senate Bill 784 (SB 784) passed the California Senate last month and the California Assembly is quickly moving a slightly amended version of the bill through committees in July. If enacted, SB 784 would take effect on January 1, 2026.