On June 23, 2022, the Federal Trade Commission (FTC) introduced a massive, 126-page notice for a proposed rule that would, if approved, dramatically transform and complicate the process for consumers to purchase, trade-in, and finance new and used cars and trucks, and voluntary protection products like extended service contracts and GAP Waiver.

If adopted, the new regulations would increase the complexity of the car-buying process, in a way that would cost consumers extra time, create substantially more paperwork required at the dealership, and introduce new administrative burdens for small businesses that would increase the cost of cars and trucks. The new regulations would essentially treat all covered car dealerships as though they were bad actors, by imposing unnecessary and burdensome reporting requirements spanning virtually every aspect of the business. These requirements, in turn, would cascade down to the consumer in the form of more complex transactions and higher prices to cover the new administrative burdens.