Is the FTC CARS Rule Any Relation to the Proposed Vehicle Shopping Rule?
Yes. First proposed in mid-2022, the CARS Rule was initially called the Motor Vehicle Dealer Trade Regulation Rule, and was often referred to within the industry as the “Vehicle Shopping Rule.” After reviewing solicited feedback from thousands of consumers, consumer advocate groups, dealerships, automotive trade associations, and industry experts, the FTC revised the proposed rule and re-named it.
What are the Penalties for Violating the CARS Rule?
Violations of the CARS Rule constitute unfair and deceptive acts and practices under Section 5 of the FTC ACT, and the FTC can impose penalties of $50,120 per violation .
Does the CARS Rule Apply in Every State?
Yes. The CARS Rule sets forth minimum standards across the country. If a state law or regulation gives even greater protection to consumers than the CARS Rule, the state standard will take precedence over the CARS Rule to the extent that there is a conflict.
What Does the CARS Rule Require and Prohibit?
Here’s a quick overview, but we’ll take a deep dive into each of these over the coming weeks.
There are additional disclosure requirements for payment quotes and payment comparisons , in addition to those already required by Regulation M and Regulation Z.
There are recordkeeping requirements. While some of these records must be kept longer, the CARS Rule specifically requires that certain records be kept for at least 24 months.
The CARS Rule requirements cannot be waived, and merely asking a consumer to waive any provision is a violation.
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