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State Attorneys General › Unfair or Deceptive Trade Practices › Rulemaking Process

Mayer Brown

A Post-CARS Rule Brake? Not So Fast. Buckle Up for New Regulatory Activity in the Motor Vehicle Space

Mayer Brown on

The Fifth Circuit vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, determining that the FTC failed to follow its own procedural requirements...more

Morgan Lewis

Massachusetts Attorney General Issues Expansive ‘Junk Fees Rule’

Morgan Lewis on

The Attorney General of Massachusetts recently promulgated rules expanding the scope of its enforcement against alleged “junk fees,” including business practices for consumer subscriptions, renewals, and recurring charge...more

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

McGlinchey Stafford on

In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Holland & Knight LLP

Fifth Circuit Strikes Down FTC's Auto Retail Scam Rule: Key Implications for Dealers

Holland & Knight LLP on

The U.S. Court of Appeals for the Fifth Circuit on Jan. 27, 2025, vacated the Federal Trade Commission's (FTC) Rule on Combating Auto Retail Scams (CARS Rule) before it could take effect, finding that the FTC failed to follow...more

Katten Muchin Rosenman LLP

CFPB Proposes a New Rule Prohibiting Certain Contractual Terms for Consumer Financial Products

Katten Muchin Rosenman LLP on

On January 13, the Consumer Finance Protection Bureau (CFPB) published a new proposed rule attempting to ban certain contractual provisions in "take it or leave it" consumer contracts that purport to "waive substantive...more

Seyfarth Shaw LLP

Fifth Circuit Set to Weigh Challenge to FTC’s CARS Rule - Seyfarth's Future of Automotive Series

Seyfarth Shaw LLP on

The administrative challenge brought by the National Automobile Dealers Association (NADA) and another trade association against the Combating Auto Retail Scams (“CARS”) Trade Regulation Rule, issued last year by the Federal...more

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