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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 delve into the anticipated regulatory landscape for the auto finance industry in 2025. They explore the potential agendas of federal and state regulators, including the Consumer Financial Protection Bureau and Federal Trade Commission, and discuss the implications for compliance and litigation within the industry. They also share tips on how to future-proof your business against the evolving regulatory environment. Tune in to gain valuable insights, hear some crystal ball predictions, and prepare your business for what’s on the horizon in the world of auto finance.

On February 27, Texas State Senator José Menéndez (D) introduced Senate Bill 1736, a piece of legislation aimed at regulating convenience fees associated with electronic payments for motor vehicles. SB 1736 would allow such fees to be imposed to offset electronic payment processing costs as long as certain restrictions are met and disclosures are made. 

On January 8, Senate Bill No. 1252 (SB 1252) was introduced to the Virginia General Assembly, aiming to amend and reenact sections of the Code of Virginia related to the application of usury rates. Just two weeks ago, the bill was passed by both the House and Senate. Opponents of the bill contend that the language and effect is very unclear, but that broad language and stringent provisions could stifle innovation and ultimately harm consumers by limiting their access to credit.

In a move that could significantly impact the auto retail industry, California has introduced Senate Bill 766, known as the California Combating Auto Retail Scams (CARS) Act. Introduced by Senator Benjamin Allen (D) on February 21, this bill aims to impose stringent new regulations on auto dealers in the state, many of which echo back to the Federal Trade Commission’s (FTC) own CARS Rule.

In this episode of Moving the Metal, Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group are joined by Tom Kline, lead consultant and founder of Better Vantage Point. Tom shares his extensive experience in the auto industry, discusses the implications of the recent vacating of the CARS Rule by the Fifth Circuit, and provides insights into the most common compliance challenges faced by dealers. He also delves into the importance of having a robust compliance program and the evolving regulatory landscape. Additionally, Tom talks about his book, Tuck the Octopus, which offers valuable strategies for managing dealership operations and mitigating risks. Tune in to gain expert perspectives on staying compliant and competitive in the auto finance industry.

In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group delve into the Consumer Financial Protection Bureau’s (CFPB) recent white paper, “Strengthening State-Level Consumer Protections.” They discuss the potential roadmap for state-level enforcement over the next four years, highlighting the interplay between federal and state regulators, joint investigations, and the CFPB’s recommendations for empowering state agencies. Tune in to understand the implications for the auto finance industry and how these initiatives might shape compliance efforts across various states.

On January 29, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report analyzing the auto lending market’s impact on servicemembers. This report indicates that servicemembers face heightened financial challenges in the auto lending market, including higher loan amounts, interest rates, and monthly payments. Despite these challenges, servicemembers were less likely to experience vehicle repossessions.

Yesterday, the U.S. Court of Appeals for the Fifth Circuit issued a significant opinion vacating the Federal Trade Commission’s (FTC) Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The decision came in response to a petition filed by the National Automobile Dealers Association (NADA) and the Texas Automobile Dealers Association (TADA), challenging the procedural validity of the rule. The petitioners argued that the FTC violated its own regulations by failing to issue an advance notice of proposed rulemaking (ANPRM) before promulgating the CARS Rule. They also contended that the FTC’s cost-benefit analysis was arbitrary and capricious.

In this special year-in-review episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso from Troutman Pepper Locke’s Consumer Financial Services Practice Group delve into the significant events and regulatory changes that shaped the auto finance industry in 2024. From the Federal Trade Commission’s CARS Rule and its legal challenges to the Consumer Financial Protection Bureau’s data collection initiatives and supervisory highlights, this episode provides a comprehensive overview of the past year. Tune in to gain insights into the trends and regulatory shifts that will influence the auto finance landscape in 2025.