Compliance Alerts

October 2025

 

Effective State Changes

 

CALIFORNIA

Assembly Bill 483 was signed into law by Governor Gavin Newsom on October 10, 2025. This bill places new requirements on fixed term installment contracts. AB 483 prohibits an early termination fee unless, at the time of origination, the contract fully explains the total cost of the fee or how the fee would be calculated when the contract is terminated and the highest possible early termination fee that could be charged. Additionally, the bill prohibits an early termination fee or any similar fee that is greater than 30% of the total cost of the contract. Effective August 1, 2026.

Senate Bill 362 amends California’s Commercial Financing Law. The law prohibits lenders of commercial financing products to use the terms “rate” or “interest” in a deceptive way and requires they also disclose the Annual Percentage Rate (APR). A violation of this law would be considered an unfair, deceptive, or abusive act or practice under the California Consumer Financial Protection Law. Effective January 1, 2026.

Senate Bill 446 was signed into law amending provisions of California’s data breach notification laws. This bill requires a qualifying individual or business to disclose within 30 calendar days if a California resident’s personal information is, or was reasonably believed to have been, accessed by an unauthorized individual in a security breach. Disclosure may be delayed to accommodate law enforcement or to restore the integrity of the data system. If more than 500 California residents are affected in the breach, that notification must also be sent to the Attorney General within 15 calendar days of consumer notification. Effective January 1, 2026.

Governor Newsom signed Senate Bill 766—The California Combating Auto Retail Scams (CARS) Act—into law on October 6, 2025. Based on the FTC’s CARS Rule, the new law purports to create more transparency during the vehicle purchasing process and establishes new consumer protections. The CARS Act applies to licensed California motor vehicle dealers and others that satisfy the definition of a "dealer" under the California Vehicle Code. The bill specifically prevents dealers from tacking on add-on services and other features from which the buyer or lessee would not benefit. Amongst other provisions, it requires clear disclosures of a vehicle’s price in advertisements, written communications, and other communications during negotiations with a possible consumer. Finally, the Act provides buyers and lessees a new 3-day right to cancel their purchase or lease of a used vehicle having a retail price equal to or less than $50,000. Effective October 1, 2026.

 

MAINE

The Maine Department of Administrative and Financial Services has issued new regulations governing the collection and remittance of sales and use taxes on vehicle leases and rentals. These rules, which clarify how taxes should be calculated and who is responsible for payment, apply to leases and rentals of tangible personal property. Effective January 1, 2025.

 

OHIO

Per Ohio Rev. Code § 4517.261, the Documentary Service Charge is to be annually adjusted using the most recent consumer price index—for 2026, a dealer can charge $398.00. Effective January 1, 2026.

 

SOUTH CAROLINA

On October 1, 2025, the South Carolina Department of Insurance adopted Orders 2025-003, 2025-004, and 2025-005 confirming Prima Facie Credit A&H and Credit Property insurance rates for 2026.

Under Order 2025-003, the Credit A&H rates for insurance sold in conjunction with consumer credit transactions in 2026 will decrease from the rates in 2025. The 12-month rate per $100 of Initial Insured Indebtedness will be as follows:

  • 14-day Retro: $0.89
  • 30-day Retro: $0.84

Under Order 2025-004, the 3-day retroactive A&H rate for insurance sold in conjunction with loans will decrease to $0.17 per $5.00 of monthly indemnity.

Under Order 2025-005, credit property rates have decreased for Automobile Fire and Theft, Automobile Collision, and Household Goods – Dual Interest. The rate for Household Goods – Single Interest remains the same. Effective January 1, 2026.