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In this episode of Moving the Metal, hosts Brooke Conkle and Chris Capurso are joined by Troutman colleagues Chris Carlson and Nam Kang from the firm’s RISE Practice Group to unpack what “Trump 2.0” really means for dealers and auto finance companies. With the Consumer Financial Protection Bureau (CFPB) and other federal regulators pulling back, the group explains how state attorneys general (AGs) and state financial regulators are rapidly filling the void — often led by former CFPB staff now embedded in state offices — and why that creates a complex patchwork of unfair or deceptive acts or practices standards and enforcement approaches across 50 states. They discuss hot-button themes like affordability, junk fees, mini-CFPBs, and the growing role of state working groups, as well as how state AGs are leveraging prior CFPB theories, the California CARS rule, and copy‑and‑paste complaints.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso launch a new AI-focused segment, examining how artificial intelligence is changing auto finance through smarter chatbots and targeted advertising, digital loan applications and algorithmic decisioning, and enhanced fraud detection tools. They highlight the legal risks that come with these innovations — including unfair or deceptive acts or practices (UDAP), fair lending, bias, explainability, false positives, and increased compliance risk — and stress the importance of strong human oversight, governance, and complaint management as dealers and auto finance companies accelerate their adoption of AI in 2026.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso lay out a practical set of 2026 resolutions for dealers and auto finance companies. Chris breaks down why state law compliance should be at the top of your list, from California’s CARS rule and junk fee laws to new disclosure and renewal requirements cropping up across the country. Brooke then shifts to the federal landscape, focusing on the Fed’s recent rate cuts, what a lower-rate environment could mean for auto loan refinancing, and the compliance risks that come with more paperwork. The discussion also tackles the real-world impact of AI — how consumers are using it in disputes and litigation, and how companies must carefully govern their own AI tools, including chatbots. Finally, they underscore the importance of a robust consumer complaint process as an early-warning system and a powerful tool to prevent small issues from turning into lawsuits.

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.

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.

As of April 27, 2025, the Federal Trade Commission (FTC) had not filed a petition for a writ of certiorari to appeal the Fifth Circuit’s decision vacating the Combating Auto Retail Scams Trade Regulation Rule (CARS Rule). The ruling, which was issued in response to a petition by the National Automobile Dealers Association and the Texas Automobile Dealers Association, challenged the procedural validity of the FTC’s rulemaking process. The court found that the FTC failed to issue an advance notice of proposed rulemaking as required leading to the vacating of the rule.

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. 

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.