We are excited to share an important milestone in our journey: AFIP and ADCO are now officially one company. This unification brings together two trusted leaders in dealership compliance, education, and risk management, creating a stronger, more comprehensive organization to serve compliance officers, agents, F&I professionals, and dealership leadership nationwide. By combining our expertise and resources, we are enhancing the quality, depth, and reach of our training, certifications, and compliance tools.
Moving forward, ADCO will continue as the professional association for compliance officers, providing a collaborative community, industry-leading webinars, and advanced compliance education, while also expanding opportunities for F&I professionals to strengthen their knowledge of both operational and sales compliance. Together, AFIP, ADCO and Federal Regulatory Automotive Training (FRAT) will now offer a more streamlined experience, broader educational pathways, and a unified voice for dealership compliance—supporting each of you as the first line of defense and advancing compliance the right way.
AFIP / ADCO Exhibiting at NADA
AFIP and ADCO are excited to announce that we will be exhibiting at NADA 2026, February 3–6! Be sure to stop by our booth, 6521N, to visit with Shannon, Tevis, Lindsey, and EJ, and check out our new look as we move forward together as one unified organization. While you’re there, enjoy a free demo of FRAT (Federal Regulatory Automotive Training) and see firsthand how our training platform helps simplify compliance, strengthen accountability, and support your team. As a bonus, all visitors to our booth will be eligible to enter a drawing to win a Jimi Hendrick Montblanc pen.
Come connect with us, explore our tools, and discover how AFIP and ADCO deliver solutions, not just software, for real-world dealership compliance.
Compliance That Works
AFIP and ADCO are proud to partner with CBT to present an ongoing series of compliance webinars designed to spotlight real-world success, best practices, and practical compliance strategies from industry professionals. These conversations are facilitated by Shannon Robertson, President of AFIP/ADCO, and feature experienced compliance leaders, many of whom are members of our association.
We recently kicked off the series with Jim Cochran, EVP of Ramey Ford, who shared valuable insights into building and sustaining an effective compliance culture. The recording of this session is available through the ADCO Compliance Forum, or you may contact any member of our team to have the link forwarded to you.
Upcoming featured speakers include:
- Joshua Duhon
- Mikelle Barnhart
- Patrick O’Hara
- Kyle Sipples
- Kerry Jacobs
- Montana Annicchiarico
- Steve Abernethy
- Patrick Butler
This webinar series reflects our commitment to providing meaningful, experience- driven education that strengthens dealership compliance programs and supports compliance professionals as the first line of defense.
The Extended Life of CARS: The Rule Is Gone, but the Risk Remains
Although the FTC’s Combating Auto Retail Scams Rule (the “CARS Rule”) was set aside by the Fifth Circuit on January 27, 2025, the regulatory concerns that prompted it remain very much alive. The court’s decision was based on procedural issues in how the rule was issued, not on the validity of the consumer protections it sought to establish. As a result, while the CARS Rule never became enforceable, federal and state regulators continue to focus on dealership practices involving pricing transparency, add-on products, advertising accuracy, and consumer disclosures.
The ruling did not weaken the FTC’s authority to pursue unfair or deceptive acts or practices under existing law, nor did it limit the enforcement powers of state regulators. In short, the rule may be gone, but the expectations behind it are not.
What Still Applies to Dealers
Even without the CARS Rule, dealerships remain fully subject to the Federal Trade Commission Act’s prohibition against unfair or deceptive acts or practices (UDAP). These provisions already address much of the conduct the CARS Rule was intended to regulate, including:
- Adding fees or products without clear disclosure
- Using bait-and-switch tactics
- Selling add-on products that provide little or no consumer benefit
- Misrepresenting vehicle prices or financing terms
- Advertising vehicles that are not actually available at the promoted price
Many of the same compliance risks continue to exist under current law, even without a new rule on the books. State Attorneys General: A Growing Enforcement Force State Attorneys General are increasingly active in policing dealership conduct, and many viewed the CARS Rule decision as a setback to consumer protection efforts. Nineteen states publicly supported the FTC’s position, citing ongoing consumer complaints tied to misleading pricing, hidden fees, and forced add-ons.
State Legislatures Are Filling the Gap
In parallel with increased enforcement, state legislatures are advancing statutory requirements that reflect the consumer protection principles underlying the FTC’s CARS Rule.
The Extended Life of CARS: The Rule Is Gone, but the Risk Remains
California introduced Senate Bill 766 in early 2025, its own version of a “CARS Act.” The bill requires clearer price disclosures, prohibits misleading information, restricts add-on products that lack consumer benefit, and introduces a three-day right of cancellation for used vehicles. This benefit, which requires dealers to allow returns without cause (within 3 days/400 miles), aims to curb deceptive practices. Set to take effect October 1, 2026, it is expected to significantly impact auto retail practices in California and goes even further than the FTC’s proposal.
Recent cases demonstrate how aggressively states are already enforcing these principles:
- In late 2024, the FTC and the Illinois Attorney General reached a $20 million settlement with a dealership group accused of advertising low prices while requiring consumers to purchase add-on products or charging for them without consent. The dealerships were also required to change how pricing was disclosed in advertising and financing discussions.
- In Arizona, a $2.6 million settlement addressed allegations of misleading online pricing and mandatory add-on charges, along with concerns about disparate financial impacts on Latino consumers.
- New York settled with dealerships accused of inflating lease-end purchase prices and adding unexpected fees.
- Pennsylvania brought suit against a used car dealer for selling vehicles “as-is” without properly disclosing known defects or providing proper title documentation.
- Pennsylvania later amended its Automotive Industry Trade Practices law to expand what qualifies as advertising and to require disclosures of known vehicle conditions such as flood damage or structural defects.
- Massachusetts issued a regulation in 2025 requiring sellers to disclose the “total price” of a product, including all mandatory fees and add-ons, mirroring the pricing transparency principles behind the CARS Rule.
These actions show that state regulators are not waiting on federal rulemaking. They are actively using existing consumer protection laws to pursue dealerships they believe are engaging in deceptive practices.
The Extended Life of CARS: The Rule Is Gone, but the Risk Remains
What This Means for Dealerships
Dealerships should continue to evaluate and strengthen compliance practices around:
- Transparent pricing and advertising
- Clear disclosure of total vehicle cost
- Proper presentation of add-on products
- Avoiding forced or misleading fees
- Honest representation of vehicle condition
- Fair and consistent treatment of all consumers
Conclusion
The CARS Rule may be off the table, but its influence lives on through existing federal UDAP laws, aggressive state enforcement actions, and new state legislation. Compliance expectations have not relaxed; they have simply shifted.
The smartest strategy is not to view the CARS Rule as a failed initiative of the FTC, but as a blueprint for what regulators already expect responsible dealerships to be doing. Pricing transparency, ethical sales practices, and consumer-first disclosures are no longer just best practices—they are the foundation of modern dealership compliance. This is not new compliance; these are the same illegal and unethical practices that have haunted our industry for years, damaging its reputation and overshadowing the tremendous opportunity and professionalism the automotive industry truly offers.
By Linda J. Robertson | Executive Director, ADCO
