Author: andy

Effective State Changes

COLORADO

The Colorado Department of Revenue recently released Regulation 1 CCR 204-10, Rule 34, which establishes provisions for vehicle dealer issuance of online temporary registration permits and protocols for when the system is offline. Effective September 30, 2026.

DELAWARE

House Bill 380 updates Delaware’s personal data privacy law by lowering business thresholds for applicability and expanding definitions related to adverse actions. The bill also requires data controllers to conduct risk assessments and implement third-party data protection agreements. Effective January 1, 2027.

HB 381 requires the notification of Delaware’s Attorney General when a data breach occurs. Effective September 2, 2026.

Senate Bill 286 makes all-terrain vehicles, off-highway vehicles, and side-by-side vehicles subject to the new recreational vehicle provisions under Delaware law. This bill amends requirements pertaining to manufacturer-dealer agreements, and mandates manufacturer compensation to dealers providing warranty services. Effective August 20, 2026.

INDIANA

Indiana published LSA Document #26-204, which implements certain bracket updates, including:

• The graduated rate thresholds for sales and loans stay the same at $2,600/$5,200.
• The minimum credit service charge for sales increases to $66.00.
• The maximum delinquency charge for sales and loans increases to $22.00.
• The minimum finance charge for loans increases to $66.00.
• The maximum loan term is 37 months for loans with principal amounts greater than $1,320 up to and including $5,200, and 25 months for loans with principal amounts of $1,320 or less.

Effective January 1, 2027 – December 31, 2028.

LOUISIANA

The Louisiana Office of Financial Institutions (“OFI”) publishes a new maximum outstanding principal balance for deferred presentment transactions and small loans on or before September 1st of each year. The maximum outstanding principal balance is calculated by applying the increase or decrease of the Consumer Price Index for the previous calendar year. For September 1, 2026, through August 31, 2027, the maximum outstanding principal balance for a deferred presentment transaction increases from $720.00 to $740.00. For a small loan made during that timeframe, it increases from $360.00 to $370.00. Effective September 1, 2026.

NEW MEXICO

New Mexico’s Attorney General promulgated Regulation 12.2.4 to update the rules around vehicle dealer advertising and sales. The rule bans deceptive practices such as misrepresenting a vehicle’s condition or hiding fees or finance charges. Additionally, the regulation requires a disclosure of a total cash cost, excluding specified taxes and fees, and enforces federal financing disclosure requirements. Effective September 9, 2026.

UTAH

The Utah Department of Commerce, Division of Consumer Protection published Regulation R152-20 to enforce the state’s motor vehicle Lemon Law. The new rules set requirements for replacing or refunding a defective vehicle amongst other provisions. Effective August 19, 2026.

 

Reminders

CALIFORNIA

The Combating Auto Retail Scams (“CARS”) Act takes effect October 1, 2026. The law addresses dealer representations, required disclosures, add-on products, payment disclosures, translation requirements, record retention, and adds a three-day cancellation right for certain used-vehicle transactions at or under $50,000. Effective October 1, 2026.

Effective State Changes

DELAWARE

HB 348 updates the state’s electric vehicle rebate program by providing the Delaware Department of Natural Resources and Environmental Control with additional flexibility to set rebate amounts and allow enhanced rebates for lower income families. It also expands eligibility to participate in the rebate program to businesses, nonprofit organizations, educational institutions, and local or state government entities. Effective July 23, 2026.

LOUISIANA

HB 989 raises the convenience fee that public license tag agents collect from $23 to $27 for registering vehicles. Effective August 1, 2026.

OREGON

Regulation 735-018-0065 establishes standards for dealerships and financial institutions using electronic signatures on official vehicle titles and registration documents for sales or leases. Effective September 1, 2026.

PENNSYLVANIA

HB 1860 permits employees of entities licensed under the Pennsylvania Motor Vehicle Sales Finance Act to work from an off-site location. Effective September 18, 2026.

 

Effective State Changes

CONNECTICUT

SB 413 revises numerous motor vehicle statutes recommended by the Department of Motor Vehicles. This bill requires motor vehicle dealers to include any dealer conveyance or processing fee in the advertised or quoted vehicle price. Effective, in part immediately.

ILLINOIS

Illinois HB 228 amends the Consumer Fraud and Deceptive Business Practices Act to prohibit advertising, displaying, or offering a price for goods or services that excludes mandatory fees or surcharges, other than governmental taxes. The law establishes disclosure requirements and exceptions for certain industries and providers. While the bill is not directed at consumer lending calculations or disclosures, dealers and other businesses that advertise consumer pricing may wish to review their advertising and fee disclosure practices in light of the new requirements. Effective July 1, 2027.

HB 5290 modernizes the Sales Finance Agency Act by expanding licensing, examination, and enforcement requirements for sales finance agencies and increasing certain civil penalties for violations, which includes purchasing a retail installment contract that violates the Retail Installment Sales Act or the Motor Vehicle Retail Installment Sales Act. The bill generally applies to non-bank purchasers and holders of Illinois retail installment contracts, while expressly exempting credit unions, banks, and certain other depository institutions from its provisions. Effective June 26, 2026.

SB 315 creates the “Artificial Intelligence Safety Measures Act”, requiring certain large AI developers to implement and disclose AI safety and risk mitigation frameworks, report critical safety incidents, and comply with new governance requirements. While the law primarily applies to large AI developers, it reflects the growing regulatory focus on AI oversight and may be of interest to companies evaluating or deploying AI tools. Effective January 1, 2027.

SB 3561 establishes the “Buy-Now-Pay-Later Consumer Protection Act”. The law defines a “buy-now-pay-later loan” as closed-end credit provided to a consumer at the time of a transaction in connection with a purchase of goods or services that is payable in four or fewer installments or within 120 days of origination. The law requires lenders of these loans to be licensed with the Department of Financial and Professional Regulation, exempts these loans from other installment and payday lending laws, and excludes merchants who facilitate loans to consumers from licensed lenders. Effective June 25, 2026.

INDIANA

On July 1, 2026, the Auto Dealer Services Division of the Indiana Secretary of State announced an adjusted maximum Documentation Preparation Fee of $261.72—raising it from $251.05. Effective July 1, 2026.

On June 24, 2026, the Indiana Department of Financial Institutions’ (“DFI”) Consumer Credit Division released Advisory Letter 2026-01. The DFI reminds motor vehicle dealers that, upon prepayment in full of a consumer credit sale, the seller/creditor or the creditor’s assignee is required by law to promptly refund the consumer for any separate charge made for credit insurance or GAP. They advise purchasers of consumer credit sales to review their internal policies and procedures relating to their legal obligations and to ensure dealer agreements clearly identify the party contractually obligated to make refunds. Effective immediately.

MINNESOTA

HF 4188 expands the definition of a “Consumer small loan lender” to include arranging a small loan by facilitating, marketing, lead-generating, underwriting, or collecting on said loan, amongst other consumer protections. Entities engaged in these types of activities should consider whether they need to obtain a license under the Regulated Loan Act, if not already licensed. Effective, in part immediately.

NEW HAMPSHIRE

HB 1207 restructures the examination fee system in New Hampshire by requiring credit unions, trust companies, and family trusts to pay an annual fixed fee instead of a fee per examination, while raising licensing fees for small loan lenders, mortgage bankers, servicers, and brokers, as well as money transmitters. Effective in part on October 1, 2026.

NEW JERSEY

New Jersey revamped their data protection laws with AB 5328. The bill bans the sale of sensitive personal data, mandates annual registration with the state for data brokers and data collectors engaged in selling or licensing personal data of New Jersey consumers, and establishes fines for noncompliance with the Act. Effective in part June 30, 2026.

PUERTO RICO

HB 932 amends the Small Personal Loans Act to reduce and modernize the financial requirements imposed on licensed small consumer loan lenders in Perto Rico. The prior law required a lender to maintain $200,000 in liquid assets to obtain and maintain a small-loan license; this threshold has been adjusted to $50,000 during the first two years. Additionally, the law requires that each licensee publish the maximum rate for small loans issued during the preceding week in a newspaper of general circulation, its website, or social media page. Effective June 12, 2026.

RHODE ISLAND

SB 2330 and identical bill HB 7452 authorize the Rhode Island Division of Motor Vehicles to create an electronic vehicle registration, titling, and lien system. Effective July 1, 2026.

SB 2347 and identical bill HB 8213 update rules on dealer reimbursement for manufacturer warranty work and extend certain protocols applicable to motor vehicle manufacturers to their distributors and factory branches. Effective October 1, 2026.

VERMONT

HB 211 updates data privacy laws by requiring data brokers to register with the state, disclose data practices, verify users, prohibit the abuse of data, and notify the state of a security breach. Effective in part on July 1, 2026.

SB 71 creates the “Vermont Data Privacy and Online Surveillance Act”. This bill allows consumers the right to access, correct, delete, or opt out of data sales featuring their personal data. The bill specifies the businesses which fall under its scope. Effective January 1, 2028.

Effective State Changes

CONNECTICUT

Senate Bill 4 updates the Connecticut Data Privacy Act and strengthens consumer privacy rights by requiring data brokers to register with the state and enabling consumers to request data deletion. Effective October 1, 2026.

IOWA

House File 2756 requires the licensing of service contract companies that work on motor vehicles and residential spaces. Effective January 1, 2027.

KENTUCKY

Senate Bill 219 updates Kentucky’s deferred deposit transaction laws by increasing the maximum allowable proceeds a customer may receive from $500 to $600, with an annual adjustment based on the Consumer Price Index, capped at $850. The bill also increases consumer protections and deferred deposit transaction database oversight. Effective July 15, 2026.

LOUISIANA

House Bill 545 increases the maximum origination fee that lenders can charge on a consumer loan or revolving account from $50 to $75. Effective August 1, 2026.

The Click-to-Cancel Act—established by House Bill 750—requires businesses offering automatic renewal contracts to provide advance renewal notices, clearly disclose terms, obtain consumer consent, and provide easy, low-cost cancellation methods. Effective January 1, 2027.

House Bill 888 updates dealer inventory plate rules by allowing dealers to use them on courtesy loaner vehicles, extending plate validity from five to ten days, and permitting rear-window display, amongst other provisions. Effective June 1, 2026.

Senate Bill 72 mandates a new statewide electronic system for vehicle titling, registration, and lien recording. Immunity from civil liability is provided for good-faith electronic transactions. Effective August 1, 2026, with provisions phased in by 2028 and 2031.

Senate Bill 386 creates the Louisiana Data Privacy Act, which dictates how businesses must handle residents’ personal data and grants consumers rights to access, correct, and delete their personal data and opt out of data sales and targeted ads. The law will be enforced by the Louisiana Attorney General. Effective January 1, 2027.

MARYLAND

House Bill 306 prohibits a manufacturer, distributor, or factory branch from taking negative action against a vehicle dealer for disclosing pricing information on their website, including the manufacturer’s minimum advertised pricing and the dealer’s ability to offer lower prices. Effective October 1, 2026.

 

Reminders

IOWA

HF 2329 and SF 2216 replace the tiered structure of Iowa’s Regulated Loan Act with a 3% per month (36% annual) interest rate for all loans under $30,000. Effective July 1, 2026.

NEBRASKA

LB 717 expands the scope of the Nebraska Installment Loan and Sales Act by increasing the threshold for covered consumer loans from $25,000 to $100,000. Effective July 17, 2026.

OKLAHOMA

The Department of Consumer Credit published the changes in dollar amount brackets for Retail Installment Sales and Consumer Loans. Effective July 1, 2026.

TEXAS

The Texas Office of Consumer Credit Commissioner published dollar amount brackets and ceilings subject to adjustment in the Texas Finance Code for Retail Installment Sales and Consumer Loans. Effective July 1, 2026.

Effective State Changes

ALABAMA

Following trends seen around the country, HB 351 creates the Alabama Personal Data Protection Act which establishes consumer rights regarding personal data use. Businesses would be subject to the law if they meet certain thresholds and would be required to allow consumers to access, request removal of, or opt out of certain uses of their personal data. Effective May 1, 2027.

GEORGIA

SB 384 allows owners of certain vehicles an optional five-year registration period instead of annual renewal. It also establishes new fees and other requirements for selecting the five-year registration option. Effective July 1, 2027.

IOWA

Iowa Governor Kim Reynolds signed identical bills HF 2329 and SF 2216 into law on May 2, 2026. These bills replace the tiered structure of Iowa’s Regulated Loan Act with a 3% per month (36% annual) interest rate for all loans under $30,000. In addition, the service charge for these loans has been updated to be the lesser of either 3% of the amount financed or $100. Effective July 1, 2026.

HF 2485 updates the motor vehicle dealer laws in the state of Iowa. This bill allows electronic signatures for odometer disclosures, amends dealer record storage requirements, and updates remote seller rules. Effective July 1, 2026.

MARYLAND

SB 582 prohibits unsolicited “live checks” or other negotiable instruments from being sent to consumers. Convenience checks tied to an existing credit line and pre-screened unsecured credit offers are exempt from its provisions. Effective October 1, 2026.

SB 784 repeals a Maryland law that had broadly exempted certain assignees or acquirers of mortgages, mortgage loans, and installment loans from state licensing requirements. The bill is intended as a clarifying corrective measure and removes that exemption from the Financial Institutions Article. Effective July 1, 2026.

MINNESOTA

The Minnesota Commerce Department published the periodic adjustment in dollar amounts in the Regulated Loan Act, effective July 1, 2026, through June 30, 2028. The adjustments are based on a 10% increase. The dollar amount adjustments include:

§47.59 Subd. 3	Principal Subject to 33% Interest	$1,500.00
§47.59 Subd. 3	Minimum Refund	$10.00
§47.59 Subd. 6	Default Charges	$10.40
§47.59 Subd. 6	Loan Administration Fee Threshold	$8,640.00

Effective July 1, 2026.

NEBRASKA

LB 972 creates the Recreational Vehicle Industry Regulation Act. Amongst other items, this bill requires agreements between dealers and manufacturers in order for new RVs to be sold in the state, requires warrantors to pay dealers fair compensation for warranty-related labor and parts, and updates registration, safety, and other laws related to motor vehicles. Effective three calendar months after the legislative session ends, estimated June 17, 2026.

 

Correction

TEXAS

Alternate Consumer Loans Subchapter F – §§342.251 – 342.252

Loan Amount	Acquisition Charge plus Installment Acct Handling Charge
Under $30:	$1 for each $5 cash advanced
From $30 up to $35:	12.5% cash advance plus $3 per month
From $35.01 up to $70:	12.5% cash advance plus $3.50 per month
From $70.01 up to $100:	12.5% cash advance plus $4 per month
From $100.01 up to $920:	12.5% cash advance, up to max charge of $130; plus $4 per month for each $100 cash advance
From $920.01 up to $1,840:	12.5% cash advance, up to max charge of $130; plus $4 per month for each $100 cash advance

Effective July 1, 2026.