In this mid-year roundup episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso recap the biggest developments shaping the auto finance industry in the first half of 2026, including the FTC’s widely unexpected “Notorious 97” warning letters to nearly 100 dealers, a wave of state-level UDAP enforcement actions, Senator Elizabeth Warren’s data requests targeting repossession and service member lending practices, Kentucky’s new legislative framework for GAP and vehicle financial protection products, a significant New Jersey dealer enforcement action under the state’s Consumer Fraud Act, and the growing compliance risks around fraud detection and AI use in the sales and financing process — wrapping up with a look ahead at what the second half of the year may bring.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down two significant state-level regulatory responses to the Federal Trade Commission’s (FTC) March 2026 wave of 97 warning letters targeting auto dealers — examining how Louisiana’s Motor Vehicle Commission is formally updating its advertising regulations to align with FTC guidance on total price transparency, and how the Massachusetts Attorney General’s Office issued a sweeping advisory putting dealers on notice that hidden documentation fees violate state law, with potential double exposure under both motor vehicle dealer regulations and the Massachusetts UDAP statute.

Louisiana and Massachusetts have each recently issued guidance addressing motor vehicle dealer advertising practices, particularly around the disclosure of fees in advertised vehicle prices. Both actions follow the Federal Trade Commission’s March 13, 2026 “Notorious 97” warning letters to auto dealership groups nationwide (discussed here) and reflect ongoing efforts at the state and federal level to ensure that advertised prices accurately reflect the total cost consumers will be required to pay.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a New Jersey enforcement action against a dealer group that began with a 2018 consent order and escalated into a 2023 complaint packed with Consumer Fraud Act allegations — from gray market disclosures and duplicative add-ons to odometer violations and improper warranty sales. The trial court initially imposed over $10 million in penalties before two rounds of reconsideration brought the final figure down to $155,000, offering a striking look at how courts balance deterrence, proportionality, and ability to pay. Tune in for a practical breakdown of what this case means for dealers navigating compliance in an era where state enforcement is quickly becoming the front line.

Last month, the New York City Department of Consumer and Worker Protection (DCWP) announced a significant enforcement action against 2541 E Tremont Ave Auto, LLC, which operated as “Honda of the Bronx.” DCWP alleged that the Bronx-based used auto dealer engaged in a pattern of deceptive practices, including bait‑and‑switch pricing, hidden financing costs, and “cancellation traps,” in violation of New York City’s consumer protection laws. The dealership admitted wrongdoing and agreed to pay a total of $129,999, consisting of $61,499 in civil penalties and $68,500 in restitution to affected consumers.

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso are joined by partner Brian Casey to unpack Kentucky SB 158, a new law creating a comprehensive framework for vehicle financial protection products, including GAP waivers, excess wear and tear waivers, and vehicle value protection agreements. They explain how SB 158 designates these products as “not insurance,” imposes clear optionality and disclosure requirements, mandates a 30-day free look period, and addresses how benefits and refunds work — particularly in repossession scenarios. They also discuss what dealers, lenders, and administrators should do now to update forms, contracts, and processes, and how Kentucky’s approach may become a model for other states considering regulation of auto add-on products.

In a recent decision from the Eastern District of Virginia, the court dismissed Fair Credit Reporting Act (FCRA) claims brought by a consumer who never received the vehicle he attempted to purchase with an auto loan. Despite acknowledging the underlying fraud in the transaction, the court held that the dispute over whether the consumer still

In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a major FTC–Maryland AG settlement with multiple auto dealerships over alleged deceptive pricing, unauthorized add-ons, and misleading financing practices. Brooke and Chris walk through the redress and penalty structure and explain how “total price,” clear disclosure, and express informed consent are being enforced post-CARS Rule. They also discuss what dealers and auto finance companies should do now to strengthen compliance, documentation, and oversight of dealer practices.

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.