Page 36 - Summer 2024

Continued from page 35.

Please note that in these legal actions against these auto dealerships, the FTC and
associated attorney general named specific store managers and sued them for
specific acts and practices alleging the same violations and misrepresentations
outlined in the postponed CARS Rule.

In addition to the postponed CARS Rule and existing FTC Act, regulatory concerns
from Georgia’s attorney general and the Consumer Financial Protection Bureau
(CFPB) also exist, demonstrated in the following example:

CFPB Orders Toyota Motor Credit to Pay $60 Million for Illegal
Lending – November 20, 2023

“Lender directed customers to dead-end cancellation hotline, withheld
refunds, and knowingly tarnished credit reports with false data. The
Consumer Financial Protection Bureau (CFPB) today ordered Toyota
Motor Credit Corporation to pay $60 million in consumer redress and
penalties for operating an illegal scheme to prevent borrowers from
cancelling product bundles (Add-On F&I Products) that increased
their monthly car loan payments. The company withheld refunds or
refunded incorrect amounts on the bundled products and knowingly
tarnished consumers’ credit reports with false information. The CFPB
is ordering Toyota Motor Credit to stop its unlawful practices, pay $48
million to harmed consumers, and pay a $12 million penalty into the
CFPB’s victims relief fund.” 7

Considering all the information presented here, what could every auto dealer in the
metro-Atlanta area be doing today to help better position their business for success?

Education regarding compliant
business best practices.

Consider studying the CARS Rule and the legal actions already taken against
auto dealerships to better understand the impact certain business practices
may have on your operations and overall financial health.

Brown & Brown Dealer Services offers regular compliance training and
education to customers, including a recent comprehensive webinar series
focused on understanding the various aspects of the FTC CARS Rule.
36 Continue on page 38.

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