< class="page-title"> The CARS Rule Is Gone, the CARS Act Is Here: Why California’s New Law Reshapes Compliance for Dealers Everywhere on October 1
Blog > The CARS Rule Is Gone, the CARS Act Is Here: Why California’s New Law Reshapes Compliance for Dealers Everywhere on October 1

    The CARS Rule Is Gone, the CARS Act Is Here: Why California’s New Law Reshapes Compliance for Dealers Everywhere on October 1

    • Greg Becker

    When the Fifth Circuit vacated the FTC’s nationwide CARS Rule in January 2025 (Crowell & Moring) — a rule that never actually took effect — many dealers assumed the threat of heavy-handed pricing regulation had quietly disappeared. That relief proved premature. California picked up the framework, added strict used-car parameters, and passed Senate Bill 766: the California Combating Auto Retail Scams (CARS) Act. 

    Here is what SB 766 actually does: 

    1. Takes effect October 1, 2026, after being signed by Governor Newsom on October 6, 2025 (SB 766). 
    2. Requires a legally defined “total price” on any advertisement or listing that references a specific vehicle (Auto Legal Group). 
    3. Creates a mandatory three-day right to cancel on qualifying used vehicles priced at $50,000 or less (SB 766). 
    4. Imposes a two-year record-retention requirement covering advertisements and price communications (SB 766, §1784.44).

    It is worth remembering that SB 766 was modeled on the FTC’s own CARS Rule (Hudson Cook), so the framework California codified is the one federal regulators already wanted. 

    Dealerships operating outside California might assume a state-level rule doesn’t reach them​ — and on the letter of the law, that’s often true. But the practical picture is more complicated. Cross-state dealer groups, digital rooftops selling across borders, and out-of-state trade-ins are increasingly common, and California has a long history of setting consumer-protection standards that other states later adopt. The dealers who treat this purely as a distant, local concern may be the ones scrambling when similar requirements show up in their own markets. 

    Total pricing transparency now has to hold across every consumer-facing platform. In plain terms, the defined total price means: ​

    • no hidden markups, 
    • no unbundled mandatory dealer add-ons, and 
    • no pre-deducted rebates the average consumer would never qualify for. 

    If your internet department, your third-party syndication feeds, and your physical showroom displays aren’t presenting the exact same numbers, you are exposed. 

    Solving that synchronization challenge requires structural alignment at the inventory and software layers, and this is precisely where a unified platform earns its keep. ProMax Complete standardizes the total-price calculation before inventory is syndicated anywhere, so whether a customer encounters a vehicle on AutoTrader, Cars.com, your website, or your sales workflow, the underlying data is consistent and defensible. 

    As October 1 approaches, passive operating models are no longer viable, and the agencies are watching the entire sector closely. By relying on a unified platform that enforces total-price consistency, tracks every change at the inventory layer, and locks down an unalterable compliance archive — built on the credit and compliance credibility that has long defined NCC — your dealership can protect its revenue while delivering the clear, frictionless buying experience that modern regulation now demands. 

    Sources

    NCC and ProMax provide educational resources and platform tools for informational purposes only. While we strive to ensure the accuracy and reliability of the information provided, this content does not constitute legal advice. NCC and ProMax do not guarantee specific financing outcomes, credit approvals, or absolute regulatory compliance for individual dealership transactions. Dealership partners are solely responsible for ensuring their advertising, desking, and data-retention workflows comply with all applicable local, state, and federal laws, including the Fair Credit Reporting Act (FCRA) and the California CARS Act (SB 766). Dealerships should consult qualified legal counsel licensed in their state to review their specific operating procedures.