Enforcement Watch

DealSafe Corporation
Updated: October 22, 2026
Scope: FTC, CFPB and California actions, rules and guidance that touch auto dealers, auto lenders and the rules dealers live under (Safeguards, Red Flags, FCRA, ECOA and Regulation B, the CARS Act, state privacy law).

Each entry states what the agency announced, taken from the agency's own release or filing, and one note on why it matters at a dealership. Entries are added as they are announced. This page is general information, not legal advice. Talk to your counsel about how any item applies to your store.

Direct: auto dealers and the rules they answer to · Adjacent: fees, data and credit cases dealers should know

Direct: auto dealers and the rules they answer to

FTC settles with Greenway Auto Group (97-letter recipient) over advertised prices thousands below actual prices and fake prize mailers

October 8, 2026 · FTC · Enforcement · Auto dealer · Federal · Rules: FTC Act Sec. 5

What happened. Greenway Auto Group agreed its price ads will prominently include the actual price a consumer must pay, excluding only government-required charges. The proposed order also bars deceptive prize mailers and misrepresentations about whether charges, fees, taxes, products or services are optional or required and whether any type or source of financing is required. The complaint alleges consumers were charged more than $3,350 on average over the advertised price in over 92% of transactions (administrative, dealer, delivery and processing fees; conditional rebates in ads), fake cash-prize mailers, and that after the FTC's March 2026 warning letter Greenway added false price-transparency assurances to its websites. Vote 2-0; filed in M.D. Fla. (Orlando). Defendants per case caption: Greenway Kia and Hyundai dealership entities in Florida.

Penalty or relief. Stipulated final order for permanent injunction (proposed; force of law once approved and signed by the court): actual-price advertising, bans on deceptive prize mailers and on misrepresenting whether charges or financing are required. No monetary amount stated on the release or case page.

Why it matters to dealers. First announced FTC case against a recipient of the March 2026 letters to 97 dealer groups. Order language reaches statements about whether financing is required, which touches F&I. Source

FTC dismisses administrative complaint against Asbury Automotive Group (payment packing, unwanted add-ons)

October 5, 2026 · FTC · Case update · Auto dealer · Federal · Rules: FTC Act Sec. 5, ECOA/Reg B

What happened. Commission order of October 5, 2026 returned the matter to adjudication and dismissed the 2024 administrative complaint against Asbury Automotive Group, three Texas dealerships, and a former GM (alleged unwanted add-ons and 'payment packing'). The order cites a stay of more than two years during Asbury's federal constitutional challenge and concludes continued litigation is not in the public interest. It notes the ECOA/Reg B discrimination count was dropped in July 2025 and states the FTC remains committed to price transparency for auto dealers, citing the March 2026 warning letters and the Manchester City Nissan order.

Penalty or relief. None. Complaint dismissed (Docket No. 9436); no ruling on the merits.

Why it matters to dealers. Easy to misread as the FTC backing off dealers; the order itself states the FTC remains committed to price transparency for dealers. The ECOA disparate-treatment line and the existing dealer orders still apply. Source

CA DMV industry memo OLIN 2026-10: CARS Act (SB 766) implementation for dealers

September 22, 2026 · California DMV · Guidance · Auto dealer · California · Rules: CA CARS Act

What happened. CA DMV Occupational Licensing Industry Notice summarizing CARS Act requirements for dealers ahead of the October 1, 2026 operative date: total price advertising, first-written-communication price disclosure, misrepresentation bans, optional add-on disclosures and valueless add-on ban, 3-day used-vehicle cancellation option, and record retention.

Penalty or relief. None (industry notice).

Why it matters to dealers. The regulator's own summary of the California CARS Act, and the best primary source for a California dealer. Source

California joins 40-AG bipartisan settlement with Credit Acceptance over subprime auto lending (add-on packing)

September 17, 2026 · California Attorney General · Enforcement · Auto lender · California

What happened. California's AG joined a coalition of 40 attorneys general in a settlement with Credit Acceptance Corporation, a subprime auto finance company, resolving allegations that it originated loans it knew or should have known consumers could not afford. The injunctive terms address dealers deceptively packing CAC auto-loan contracts with unwanted and expensive add-ons such as service contracts.

Penalty or relief. $694M in cash and debt relief nationally per the CA AG; California consumers an estimated $1.46M restitution and $5.4M debt relief. Injunctive terms include loan-risk disclosures and measures to help guard consumers from dealers deceptively packing CAC contracts with unwanted add-ons. Subject to court approval; also resolves the suit first filed by the CFPB and New York AG.

Why it matters to dealers. The settlement specifically addresses dealer add-on packing on financed deals. The finance company is the respondent; dealers are not named in the release. Source

FTC publishes price transparency FAQs for auto dealers

September 15, 2026 · FTC · Guidance · Auto dealer · Federal · Rules: FTC Act Sec. 5

What happened. FTC staff published FAQs on price transparency for the auto industry. Per the FTC, the advertised price must be the actual price any consumer can walk in and pay, excluding only government-required charges. Covers what the advertised price must include, doc fees, rebates and discounts, negotiations and optional items, pricing across media, in-transit vehicles. Follows the March 2026 warning letters to 97 dealer groups.

Penalty or relief. None (staff guidance, not binding on the public or the Commission).

Why it matters to dealers. The clearest current statement of what the FTC expects in dealer price advertising: for example, the full doc fee must be in the advertised price, and the actual price must be the most prominent amount on inventory and listing pages. Source

FTC, Connecticut secure $4M settlement with Manchester City Nissan over deceptive fees and unauthorized add-ons

August 19, 2026 · FTC · Enforcement · Auto dealer · Connecticut · Rules: FTC Act Sec. 5

What happened. Settles the January 2024 FTC/Connecticut suit against Chase Nissan LLC (Manchester City Nissan), its owners and managers. Alleged: double-charging to 'certify' vehicles already advertised as certified pre-owned, and fees such as total loss protection inserted into financing agreements without consumers' knowledge or consent. The FTC said the dealership's own data showed customers were frequently charged thousands in unlawful fees.

Penalty or relief. $4 million for consumer redress; no misrepresentations about certification or limited manufacturer warranty; maximum total price (excluding required government charges) as the most prominent item; express, informed consent for all charges. Stipulated final order filed in D. Conn. (entered August 20, 2026); vote 2-0. Co-plaintiff: State of Connecticut.

Why it matters to dealers. The most recent FTC monetary settlement with a dealer, and the FTC cited it in the Asbury dismissal order as an example of its continued auto price-transparency enforcement. The order terms (all-in price prominence, express informed consent for every charge) are a practical checklist for F&I and advertising. Source

FTC policy statement: no disparate-impact claims; modifies Napleton, Passport and Coulter dealer orders

August 7, 2026 · FTC · Policy statement · Auto dealer · Federal · Rules: ECOA/Reg B, FTC Act Sec. 5

What happened. FTC announced a policy statement that it will not pursue claims based on disparate-impact or 'unfair discrimination' theories. It will continue to assert disparate-treatment claims under ECOA and will treat Section 5 as a consumer-protection statute. Under the new policy the Commission reviewed past decisions based on disparate-impact statistical analyses and modified certain compliance obligations for three auto dealer matters. Vote 2-0.

Penalty or relief. No new penalty. Agreements (dated November 26, 2025, announced August 7, 2026) under which the FTC stops monitoring and enforcing the credit discrimination and fair lending program sections of three dealer orders; defendants may not challenge judgments already paid (Napleton $9.95M, Passport $3.38M, DePaola/Coulter $2.35M); the rest of each order 'shall remain in full force and effect.'

Why it matters to dealers. Directly changes how the FTC enforces ECOA/Reg B against dealers: disparate-impact theories are out, intentional (disparate-treatment) discrimination claims remain. Pairs with the CFPB's Reg B final rule (effective July 21, 2026). Source

RentGrow to pay $2.25M to settle FCRA accuracy, disclosure and dispute allegations

July 9, 2026 · FTC · Enforcement · Consumer reporting agency · Federal · Rules: FCRA, FTC Act Sec. 5

What happened. Tenant-screening consumer reporting agency RentGrow allegedly failed to maintain reasonable procedures to assure maximum possible accuracy (duplicate criminal and eviction records), failed to disclose all information and sources on consumer request, mishandled disputes by labeling them invalid, and misled consumers about dispute outcomes.

Penalty or relief. $2.25 million civil penalty; injunctive provisions on reasonable procedures for maximum possible accuracy, FCRA compliance, and no misrepresentations about updated reports after disputes. DOJ filed in D.D.C. on FTC referral; vote 2-0.

Why it matters to dealers. Dealers are users of consumer reports, not CRAs, but the case shows FCRA remains an active FTC priority with civil penalties, and the accuracy and dispute themes connect to the adverse action notices dealers send. Source

Amazon to pay $2.25M civil penalty for knowingly violating FCRA identity theft records provision (Section 609(e))

June 30, 2026 · FTC · Enforcement · Federal · Rules: FCRA

What happened. FTC alleged Amazon failed to comply with FCRA Section 609(e), which requires companies to provide identity theft victims, within 30 days of request, application and business transaction records about fraudulent transactions in their names. Per the FTC, Amazon had no written policy for 609(e) requests until early 2025.

Penalty or relief. $2.25M civil penalty. Complaint filed by DOJ on FTC referral.

Why it matters to dealers. Identity-theft fraud in car deals is common. The FTC describes 609(e) as requiring companies to give victims records of fraudulent transactions made in their names, which ties to a dealer's Red Flags program and deal-jacket records. Source

CFPB final rule amends Regulation B on disparate impact, discouragement and special purpose credit programs

April 22, 2026 · CFPB · Rulemaking · Federal · Rules: ECOA/Reg B

What happened. Final rule amending Regulation B provisions related to disparate impact, discouragement of applicants or prospective applicants, and special purpose credit programs. The rule deletes language indicating the 'effects test' may apply under ECOA and adds language stating the Act does not recognize it.

Penalty or relief. None. Final rule, 91 FR 21620, effective July 21, 2026. Proposed November 13, 2025 (90 FR 50901).

Why it matters to dealers. Dealers that arrange financing work under Regulation B. This is the regulatory change the FTC cites in its August 2026 disparate-impact policy statement, in which the FTC says it will continue to assert disparate-treatment claims under ECOA. Source

FTC, Maryland AG secure full refunds and $3.1M penalty from Lindsay Auto Group (deceptive pricing, unwanted add-ons)

April 2, 2026 · FTC · Enforcement · Auto dealer · Maryland · Rules: FTC Act Sec. 5

What happened. FTC and the Maryland Attorney General announced Lindsay Automotive Group and executives will return money to resolve allegations they advertised false low prices and added mandatory fees and unwanted add-ons. The December 2024 complaint named three dealerships, their management company, and three individuals.

Penalty or relief. Redress for consumers charged a total of more than $75M (April 1, 2020 to December 31, 2025) may be available; $3.1M civil penalty to the Maryland AG; proposed order requires providing the total price including all mandatory fees.

Why it matters to dealers. A 2026 dealer settlement on advertised price versus charged price and add-ons, with a total-price disclosure requirement. Pairs with the 97 warning letters and the price transparency FAQs. Source

LA County DA and other California DAs: CarMax to pay $1.1M over late title and registration transfers

March 25, 2026 · California District Attorneys · Enforcement · Auto dealer · California

What happened. California district attorneys alleged that in thousands of instances since 2019 CarMax failed to timely submit applications to transfer registration and ownership of used cars to the CA DMV (generally within 30 days of sale). The judgment, signed March 24, 2026 in Santa Clara County Superior Court, requires new policies such as sales holds on vehicles without title in hand or a clear path to it, adequate title staffing, and a designated senior compliance manager.

Penalty or relief. $1.1M total ($900K civil penalties, $150K costs, $50K consumer protection trust fund) plus injunctive terms.

Why it matters to dealers. California dealer enforcement by local prosecutors under state consumer protection law, with a named compliance manager as a term of the judgment. Source

FTC warns 97 auto dealership groups about deceptive pricing

March 13, 2026 · FTC · Guidance · Auto dealer · Federal · Rules: FTC Act Sec. 5

What happened. FTC sent letters to 97 auto groups nationwide warning that advertised prices must be the total price, including all mandatory fees, consumers will be required to pay. The letters cite examples including prices that omit required fees, prices reflecting rebates or discounts not available to all consumers, prices that ignore an additional required down payment, and prices conditioned on dealer financing.

Penalty or relief. None (warning letters). FTC says it will continue to monitor and take additional action as warranted.

Why it matters to dealers. A direct FTC message to dealers on advertised pricing, the precursor to the September 2026 staff FAQs, and cited in the Asbury dismissal order. Source

FTC formally withdraws the CARS Rule to conform to court decisions

February 12, 2026 · Federal Register · Rulemaking · Auto dealer · Federal · Rules: CARS

What happened. In light of federal court decisions, the FTC took final action to conform three rules to court-ordered results, including withdrawing its final rule titled 'Combating Auto Retail Scams Trade Regulation Rule' (CARS Rule). The same notice recodified the pre-2024 Negative Option Rule and removed the Non-Compete Rule.

Penalty or relief. None. Final action, 91 FR 6507, effective February 12, 2026.

Why it matters to dealers. Closes out the federal CARS Rule. The FTC continues dealer pricing enforcement under the FTC Act, and California's own CARS Act (SB 766) became operative October 1, 2026. Source

CA AG consumer alert: credit discrimination remains illegal under California and federal law

December 3, 2025 · California Attorney General · Guidance · California · Rules: ECOA/Reg B

What happened. California's Attorney General issued a consumer alert reminding consumers and lenders that credit discrimination remains illegal under both California and federal law, after the CFPB in October 2025 terminated a fair lending consent order with a credit card issuer early. The alert lists protected characteristics and forms discrimination can take (discouraging applications, less favorable terms, refusals) and states the AG will act against institutions that discriminate.

Penalty or relief. None (consumer alert).

Why it matters to dealers. The state-level counterpoint to the federal fair lending changes (CFPB Reg B rule, FTC disparate-impact statement). The CA AG says credit discrimination remains illegal under California law. Source

CFPB interpretive rule: FCRA generally preempts state laws touching broad areas of credit reporting

October 28, 2025 · CFPB · Rulemaking · Federal · Rules: FCRA

What happened. The CFPB issued an interpretive rule stating that the FCRA generally preempts state laws that touch on broad areas of credit reporting, replacing a July 2022 interpretive rule withdrawn in May 2025. California's AG responded on November 13, 2025 that California's medical debt law remains in effect.

Penalty or relief. None. Interpretive rule, 90 FR 48710.

Why it matters to dealers. Federal and state credit reporting rules are contested. Dealers who pull credit in more than one state should not assume either side's position settles the question. Source

California CARS Act (SB 766) signed: new dealer pricing, add-on and cancellation rules, operative October 1, 2026

October 6, 2025 · California Legislature · Rulemaking · Auto dealer · California · Rules: CA CARS Act

What happened. SB 766, the California Combating Auto Retail Scams (CARS) Act, regulates vehicle dealer advertising, pricing, add-on sales and recordkeeping. Per the CA DMV's implementation memo, it requires total price in vehicle-specific and financing ads and in the first written communication about a specific vehicle (including credit applications), bans misrepresentations including about consumer credit application information, requires add-ons to be disclosed as optional in at least 12-point type and bars valueless add-ons, creates a 3-day cancellation right for used vehicles priced $50,000 or less, and requires 2-year record retention.

Penalty or relief. Legislation (Chapter 354, Statutes of 2025). Approved by the Governor and chaptered October 6, 2025; operative October 1, 2026 per CA DMV OLIN 2026-10. Enforcement per DMV: existing UCL, FAL and CLRA remedies plus DMV and BAR licensing actions.

Why it matters to dealers. The most significant California dealer-specific law in the window, and it directly touches credit applications. It was signed in October 2025 and took effect October 1, 2026. Source

Adjacent: fees, data and credit cases dealers should know

Cases outside the dealership that still set the rules dealers answer to: fee disclosure, data handling, credit reporting and fair lending. One line each, with the source.

How this page is kept

Items come from the agencies' own press releases, orders and Federal Register notices. Each one is logged with its source link the week it is announced and reviewed by a person before it appears here. If you think an item is wrong or missing, write to support@dealsafe.com.

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