The back end of a car deal carries the most consumer-facing federal rules in the store. This is a plain-English overview of what governs the F&I office — financing disclosures, the Buyers Guide, the Holder Rule, add-on products, and more. No product, no pitch.
“F&I” is the finance-and-insurance desk — where the deal is financed and the back-end products are sold¹. It's also where federal consumer-protection law lands hardest: how credit is disclosed, how applications are decided, how the vehicle is described, and what a buyer can do later if something was wrong². This brief walks through the rules in plain English — what each one is, and what it asks of a dealership.
Financing terms must be disclosed clearly and uniformly — the annual percentage rate, finance charge, amount financed, and total of payments — in the federal box on the retail-installment contract, so a buyer can see the true cost of credit.
Prohibits credit discrimination and requires an adverse-action notice when an application is denied or approved on materially different terms. A dealer's fair-lending posture — including how finance-charge markup is handled — sits here.
Governs how a dealer pulls and uses credit reports: risk-based pricing notices, adverse-action notices, the Red Flags identity-theft program, and the secure disposal of report data.
Every used vehicle offered for sale must display a Buyers Guide window form stating whether it is sold “As Is” or with a warranty, and the vehicle's major systems. The posted Guide has to match what's in the contract.
Requires a notice in consumer credit contracts preserving the buyer's right to assert the same claims and defenses against the holder of the contract (the assignee or lender) that they could assert against the dealer.
Sets the rules for written warranties and service contracts — how they are labeled (full vs. limited), what must be disclosed, and the bar on conditioning a warranty on the use of a particular brand of part or service.
GAP waivers, vehicle service contracts, and other back-end products — along with payment packing and documentary (doc) fee disclosure — are governed largely by state law and unfair-or-deceptive-practices standards, which vary widely from state to state.
Buyers are screened against OFAC's Specially Designated Nationals list, and the GLBA Privacy Rule governs the privacy notices a dealer provides about sharing customer information — the privacy half of the same law behind the Safeguards Rule.
The CARS Rule — “Combating Auto Retail Scams,” 16 CFR Part 463 — was finalized by the FTC in January 2024. It would have required clearer add-on and price disclosures, express informed consent before charging for any add-on, and would have banned a list of misrepresentations in vehicle sales and financing.
It never took effect. On January 27, 2025, the U.S. Court of Appeals for the Fifth Circuit vacated the rule, holding that the FTC skipped a required procedural step. The FTC did not appeal within the window, so the rule has no force or effect today and the matter returned to the agency for reconsideration.
The federal vacatur is nationwide — but it doesn't stop states from acting, and several have. Most notably, California enacted its own California CARS Act (SB 766), signed in October 2025 and taking effect October 1, 2026. It covers much of the same ground: barring misrepresentations about price, financing, and add-ons, requiring clear-and-conspicuous disclosure that add-ons are optional, and prohibiting add-ons that provide no benefit to the buyer. A dealer's obligations now depend heavily on the state.
Status current as of June 2026. The federal rule could be revisited and state laws change — confirm current status before relying on this.
A stack of federal rules that apply once a dealer arranges financing or sells back-end products: the Truth in Lending Act (financing disclosures), the Equal Credit Opportunity Act (fair lending and adverse-action notices), the Fair Credit Reporting Act (credit-report use), the FTC Used Car Rule (the Buyers Guide), the FTC Holder Rule, and the Magnuson-Moss Warranty Act — layered on top of state law governing doc fees and add-on products.
Under the FTC Used Car Rule (16 CFR Part 455), a Buyers Guide is a window form that must be displayed on each used vehicle offered for sale. It states whether the vehicle is sold “As Is” or comes with a warranty, what percentage of repair costs a warranty covers, and the vehicle's major mechanical and electrical systems. The Guide that's posted becomes part of the contract.
The FTC Holder Rule (16 CFR Part 433) requires a specific notice in consumer credit contracts. It lets the buyer raise the same claims and defenses against whoever holds the contract — typically the bank or finance company the dealer assigns it to — that the buyer could have raised against the selling dealer.
Under ECOA and the FCRA, when a credit application is denied, or approved on materially different terms than requested, the consumer is generally entitled to an adverse-action notice explaining the decision and, where a credit report was used, the source of that information and certain rights.
Largely at the state level. Documentary (doc) fee caps, disclosure requirements, and the rules for products like GAP and vehicle service contracts vary widely by state, and all are subject to federal and state unfair-or-deceptive-practices standards. Payment packing — burying add-on costs in a monthly payment — is a recurring enforcement theme.
Not the federal one. The FTC's CARS Rule (Combating Auto Retail Scams, 16 CFR Part 463) was finalized in January 2024, but the U.S. Court of Appeals for the Fifth Circuit vacated it on January 27, 2025, finding the FTC skipped a required procedural step. The FTC did not appeal, so it has no force or effect nationwide. States are stepping in, though — California enacted its own California CARS Act (SB 766), effective October 1, 2026 — so a dealer's obligations now depend on the state. Always confirm current status before relying on it.
This brief is published by Automotive Risk Management Partners, which works across the full range of dealership obligations — OSHA, EPA, the FTC Safeguards Rule, F&I, and data security. A few companion references: