Pub. 4 2024 Issue 2

PREPARING FOR THE FTC’S CARS RULE (AKA, VEHICLE SHOPPING RULE) Key Steps Dealers Can Take Now By Mark Sanborn, Senior Product & Regulatory Counsel, ComplyAuto As you may know, the FTC CARS Rule, also known as the Vehicle Shopping Rule (“Rule”), is set to impose stringent requirements on motor vehicle dealers. With its focus on advertising practices, consumer disclosures and recordkeeping, compliance will demand significant changes in how dealerships operate. The Rule has been finalized, but its effective date has been “stayed” — that is, delayed — until the legal challenges to the Rule are resolved. While it is possible that the legal review of the Rule could succeed, forcing the FTC to return to the “drawing board,” the challenge remains that complying with the Rule’s extensive and complex requirements will take time and effort. Therefore, it is crucial for dealers to take proactive steps now to ensure they are prepared if and when the Rule ultimately takes effect. 44 MONTANA AUTO DEALER

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