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Brooke Conkle offers consumer-facing companies compliance counseling and litigation services to help them address federal and state consumer protection laws. Recognizing the challenges facing financial services companies, she provides in-depth analysis of complex issues related to consumer protection and compliance.

In this inaugural episode of Moving the Metal, Troutman Pepper attorneys Brooke Conkle and Chris Capurso examine the major requirements of the FTC’s proposed CARS Rule. After a refresher on the rule’s requirements, Brooke and Chris discuss the current status of the litigation surrounding the rule, including a discussion of the briefs and data submitted by the FTC and the trade groups fighting the rule. Tune in as Brooke and Chris look under the hood to examine the FTC’s fine print and where the rule currently stands in the courts, helping your auto finance company avoid regulatory pitfalls.

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging 2023. Courts across the country issued rulings that will have immediate and lasting impacts on the industry. Our team of more than 140 professionals has prepared this concise, yet thorough analysis of the most important issues and trends throughout our industry. We not only examined what happened in 2023, but also what to expect — and how to prepare — for the months ahead.

On October 13, California Governor Gavin Newsom signed into law Senate Bill 666, which amends the California Financing Law to prohibit a covered entity from charging certain fees in connection with a commercial financing transaction with a small business. Under the law, a small business is defined as an independently owned and operated business, with its principal office located in California, its officers domiciled in California, and, together with affiliates, 100 or fewer employees and average annual gross receipts of $15 million or less over the previous three years. “Covered entities” do not include depository institutions.