Auto Finance

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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.

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 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 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.