FTC CARS Rule
The FTC Vehicle Shopping Rule was vacated by a federal appeals court. Its specific disclosure mandates have no force or effect. Confirm the current status at ftc.gov.
Advocacy · Regulatory & Compliance
NOADA tracks the BMV, FTC, and Ohio rules that affect dealer compliance - deputy-registrar procedures, the CARS Rule, FTC Safeguards, doc fees, and advertising.
At a glance
A working reference, not legal advice - always confirm current rules and fees with the agency of record before relying on them.
The FTC Vehicle Shopping Rule was vacated by a federal appeals court. Its specific disclosure mandates have no force or effect. Confirm the current status at ftc.gov.
Dealers must maintain a written information-security program - qualified individual, risk assessments, encryption, vendor oversight, incident response.
The FTC still polices false or misleading advertising, often jointly with state attorneys general who can pursue restitution and penalties.
The Consumer Sales Practices Act governs deceptive acts in vehicle sales and advertising regardless of any federal rule. Enforced by the Ohio AG.
Now inflation-indexed and republished periodically, so the maximum changes over time. Confirm the current cap at bmv.ohio.gov and in ORC 4517.261 before setting paperwork.
Registration and deputy fees are set in statute and adjusted by budget legislation. Always confirm the current amount on bmv.ohio.gov.
Rules and fees change frequently. Verify current requirements with the FTC, the Ohio BMV (bmv.ohio.gov), your County Clerk of Courts, or qualified counsel before relying on them.
Regulation is where policy meets the showroom floor. NOADA tracks the bmv ftc dealer regulations ohio members deal with in practice - Ohio BMV and deputy-registrar procedures, federal FTC rules on advertising and data security, the documentary-fee cap, and the consumer-protection standards that govern how vehicles are sold - and translates the changes into plain language a Northeast Ohio store can act on. This page is a working reference, not legal advice; always confirm current rules and fees with the agency of record before relying on them.
For the bills behind these rules, see the legislative page. For how to weigh in, see the Action Center.
Ohio splits vehicle services across two offices, and getting this right is the foundation of compliance:
NOADA operates a deputy-registrar agency, so we work inside the BMV side of this system every day. When a rule or procedure changes on either side, we route members and their customers correctly. The differentiator article BMV vs. Clerk of Courts in Ohio explains the split in detail.
The FTC’s Combating Auto Retail Scams (“CARS”) Rule would have imposed sweeping new requirements on how dealers advertise prices, disclose add-ons, present monthly payments, and document customer communications. A federal appeals court vacated the rule after a challenge brought by dealer groups, holding that the FTC had not followed a required procedural step. As a result, the rule currently has no force or effect.
What this means for Northeast Ohio dealers: the CARS Rule’s specific federal disclosure mandates are not in effect. But the FTC retains broad authority, and the agency could restart rulemaking or pursue the same conduct through enforcement. Dealers should not read the vacatur as a green light, since Ohio’s own consumer-protection law still governs (below). Confirm the current status at ftc.gov before relying on it.
Even without the CARS Rule, the FTC exercises authority under Section 5 of the FTC Act to police false or misleading advertising. The FTC frequently partners with state attorneys general, who can pursue restitution and penalties, and joint federal-state actions against dealers can result in significant fines and customer restitution. The lesson NOADA passes to members: advertising compliance is not optional, and the cost of getting it wrong now comes through coordinated federal-state enforcement. Confirm current enforcement standards at ftc.gov and with the Ohio Attorney General.
The FTC’s Safeguards Rule under the Gramm-Leach-Bliley Act requires dealers, as financial institutions, to maintain a written information-security program protecting customer data - including a designated qualified individual, risk assessments, access controls, encryption, vendor oversight, and an incident-response plan. This rule is in effect and actively enforced. NOADA’s member services support compliance here, including the secure document-shredding program with the annual audit many stores use for their compliance file. See Dealer Services: Compliance.
Deputy registrars operate under contract with the Ohio Department of Public Safety, awarded through a competitive RFP on a regular cycle, and follow an extensive set of BMV procedures governing identity verification, document handling, fraud detection, and transaction processing. Staff pass background checks. These procedures change regularly. Because NOADA runs the Akron BMV, members get accurate, current guidance on what the counter requires for a given transaction - see What to bring to the BMV.
Ohio registration and deputy-registrar service fees are set in statute and are adjusted through budget legislation from time to time. Fees change, so always confirm the current amount on bmv.ohio.gov or our Akron BMV fees page before quoting a customer. The underlying funding debate, whether the deputy fee is high enough to keep local offices open, is covered on the legislative page.
REAL ID compliance affects what your customers need to board domestic flights and enter federal facilities. Converting a standard license to a REAL ID-compliant credential must be done in person at a deputy registrar, with specific proof of identity, Social Security number, and Ohio residency. NOADA’s consumer guide REAL ID Ohio required documents keeps the current checklist; the rules and acceptable documents are set federally and by the Ohio BMV.
Ohio law caps the documentary service charge a dealer may collect. Recent legislation replaced the long-standing fixed cap with an inflation-indexed figure that is recalculated and republished periodically. Because this number moves over time, NOADA advises members to confirm the current cap at bmv.ohio.gov and in Ohio Revised Code 4517.261 before setting deal paperwork. Do not rely on a figure from a prior period.
Ohio’s Consumer Sales Practices Act (CSPA) governs deceptive and unconscionable acts in consumer transactions, including vehicle sales and advertising. It applies regardless of the status of any federal rule, and the Ohio Attorney General enforces it. This is the backstop that makes advertising compliance a year-round obligation, not a federal-rule question.
Ohio law has addressed dealer liability for third-party vehicle-history reports (such as Carfax or AutoCheck), clarifying that a dealer is responsible for information the dealer provided, but not for errors or omissions in data supplied by others - while remaining subject to the CSPA. NOADA helps members understand how to use and disclose these reports correctly.
This page is a general reference for NOADA members and the public. It is not legal advice. Rules and fees change frequently - verify current requirements with the FTC, the Ohio BMV (bmv.ohio.gov), your County Clerk of Courts, or qualified counsel before relying on them.
Is the FTC CARS Rule in effect? No. A federal appeals court vacated it, so its specific requirements are not in force. The FTC could restart rulemaking or pursue similar conduct through Section 5 enforcement, and Ohio’s Consumer Sales Practices Act still applies. Confirm the current status at ftc.gov.
Does the FTC Safeguards Rule still apply to dealers? Yes. The Safeguards Rule remains in effect and requires a written information-security program. It is unaffected by the CARS Rule vacatur.
What is the current Ohio doc-fee cap? Ohio’s documentary service charge is now indexed to inflation and republished periodically, so the maximum changes over time. Confirm the current cap at bmv.ohio.gov and in Ohio Revised Code 4517.261 before quoting it.
Does the BMV issue car titles? No. In Ohio, titles are issued by the County Clerk of Courts title office; the BMV deputy registrar handles registration, plates, and licenses/IDs. See BMV vs. Clerk of Courts in Ohio.
Where do I confirm current BMV fees and forms? Always use bmv.ohio.gov or our Akron BMV fees page, since fees and forms change.
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