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The Ghost of CARS Rule Past: FTC and Connecticut Team Up on Junk Fees

By Brooke Conkle & Chris Capurso on September 22, 2026
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In this episode of Moving the Metal: The Auto Finance Podcast, hosts Brooke Conkle and Chris Capurso break down a recent $4 million settlement between the FTC and the Connecticut Attorney General’s Office against an auto dealership accused of deceptive pricing, unauthorized add-on charges, and phantom vehicle certifications. They discuss the significance of naming individual owners and managers as defendants, the growing coordination between federal and state regulators using UDAP authority to enforce what amounts to the “ghost” of the vacated FTC CARS Rule, and why junk fees, price transparency, and express informed consent remain top enforcement priorities regardless of administration. The hosts close with practical takeaways for dealers and finance companies on aligning advertising, add-on sales practices, and compliance monitoring to avoid similar exposure, including private litigation risk under state consumer protection statutes and the Holder Rule.

Transcript: The Ghost of CARS Rule Past: FTC and Connecticut Team Up on Junk Fees (PDF)

Photo of Brooke Conkle Brooke Conkle

Brooke Conkle offers consumer-facing companies compliance counseling and litigation services to help them address federal and state consumer protection laws. Recognizing the challenges facing financial services companies, she provides in-depth analysis of complex issues related to consumer protection and compliance.

Read more about Brooke ConkleEmailBrooke's Linkedin Profile
Photo of Chris Capurso Chris Capurso

Chris focuses his practice on consumer financial services compliance, guiding clients through the many federal and state laws and regulations that impact consumer credit programs.

Read more about Chris CapursoEmailChris's Linkedin Profile
  • Posted in:
    Administrative and Regulatory, Corporate Governance and Compliance
  • Blog:
    Consumer Financial Services Law Monitor
  • Organization:
    Troutman Pepper Locke
  • Article: View Original Source

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