August & September 2025 Compliance Updates

Effective State Changes

ARIZONA

The State of Arizona’s Department of Insurance and Financial Institutions published on July 31, 2025, matters in regard to new prima facia credit life insurance and credit disability rates.

Credit disability rates are changing as follows:

For Class 1 – Credit Unions – Rates Per $100 Per Annum

14 Retro: $1.33
14 Elim: $1.14
30 Retro: $1.22
30 Elim: $0.84

For Class 2 – Banks, Savings and Loans Institutions and Mortgage Companies – Rates Per $100 Per Annum

14 Retro: $0.80
14 Elim: $0.69
30 Retro: $0.74
30 Elim: $0.51

For Class 3 – Finance Companies, Small Loan Companies, and A.R.S. 6-601(5) Consumer Lenders – Rates Per $100 Per Annum

14 Retro: $0.94
14 Elim: $0.81
30 Retro: $0.87
30 Elim: $0.60

For Class 4 – Dealers, Including Auto, Truck, and Boat Dealers, Retail Stores and other persons selling financed goods – Rates Per $100 Per Annum

14 Retro: $0.34
14 Elim: $0.29
30 Retro: $0.31
30 Elim: $0.21

For Class 5 – All other persons selling credit insurance not specifically listed in the above classes – Rates Per $100 Per Annum

14 Retro: $0.80
14 Elim: $0.69
30 Retro: $0.74
30 Elim: $0.51

 

Credit life rates are changing as follows:

  • Monthly Outstanding Balance:
    • Single Life: $0.84 per month per $1,000 of outstanding insured debt
    • Joint Lives: $1.39 per month per $1,000 of outstanding insured debt
  • Single Premium:
    • Single Life
      • Decreasing Term Life: $0.36 per year per $1000 indebtedness
      • Level Term Life: $0.83 per year per $1000 original indebtedness
    • Joint
      • 1.65 times (or 165%) of the single life rate

Effective February 1, 2026.

MISSISSIPPI

Pursuant to SB 2803, the Mississippi State Tax Commission finalized regulations (35.VI.1.05) to establish a new exemption for ATVs from ad valorem tax when held by a retailer on a consignment or floor plan basis. An ATV is defined as a motor vehicle that is designed for off-road use and is not required to have a motor vehicle road or bridge privilege license. The ATV designation includes utility task vehicles, also known as side-by-sides, but does not include electric bicycles. Effective January 1, 2026.

NEW HAMPSHIRE

SB 156 allows the Division of Motor Vehicles to contract with a third-party vendor to facilitate the secure electronic transfer of title applications and information. Effective September 13, 2025.

NEW JERSEY

SB 3309 creates the “Motor Vehicle Open Recall Notice and Fair Compensation Act” which changes a franchisor’s compensation for work done by motor vehicle franchisee dealers related to a warranty or manufacturer recall. Effective January 1, 2026.

July 2025 Compliance Updates

Effective State Changes

DELAWARE

HB 164 institutes an additional registration fee on owners of electric motor vehicles, plug-in electric motor vehicles, non-plug-in electric motor vehicles, and alternative-fuel motor vehicles. Additionally, the bill increases the document fee from 4.25% to 5.25% of the motor vehicle purchase price. Effective October 1, 2025.

ILLINOIS

As published in Company Bulletin 2025-14 by the Illinois Department of Insurance the updated prima facie credit insurance rates will become effective August 21, 2025.

Credit life prima facie rates are decreasing, as follows:

  • Monthly Outstanding Balance: $0.70 per month per $1,000 of outstanding insured debt on single life
  • Single Premium Decreasing Term Life: $0.46 per year per $100 indebtedness
  • Level Term Life: $0.92 per year per $100 original indebtedness

Joint credit life rate shall be 1.67 times the appropriate single life rate.

Rule effective May 22, 2025; New rate filing effective August 20, 2025.

INDIANA

On July 1, 2025, the Auto Dealer Services Division of the Indiana Secretary of State announced an adjusted maximum Documentation Preparation Fee of $251.05—raising it from $245.28. Effective July 1, 2025.

LOUISIANA

Beginning January 1, 2026, HB 476 establishes an annual adjustment to the credit investigative fee for motor vehicle purchases, calculated as the lesser of the cumulative percentage change in the Consumer Price Index for All Urban Consumers (CPI-U) over the previous year or a 3% growth rate. Effective August 1, 2025.

HB 582 requires the Office of Financial Institutions to calculate a new outstanding principal balance allowed for deferred presentment transactions and small loans on or before September 1 each year, based on the change in the CPI-U for the previous calendar year. Effective August 1, 2025.

RHODE ISLAND

SB 229 and companion bill, HB 5042, repeal the provisions in the law allowing deferred deposit lenders and transactions. Effective January 1, 2027.

TEXAS

HB 700 establishes various requirements related to commercial sales-based financing, including specific financial disclosures that must accompany an offer of commercial sales-based financing of less than $1 million and the registration of commercial sales-based financing providers and brokers with the Office of Consumer Credit Commission. Effective September 1, 2025.

WISCONSIN

SB 45 is the executive budget act of the 2025 Wisconsin legislature. The bill increases the title fee for motor vehicles in the state. Title fee increase effective October 1, 2025.

June 2025 Compliance Updates

Effective State Changes

GEORGIA

SB 81 provides new protections for consumer data linked to motor vehicle sales or leases. In addition, the law creates new standards for the use of motor vehicle dealer data collected by third parties or maintained by dealers. Effective July 1, 2025.

HAWAII

SB 1367 reorganizes and clarifies a number of provisions of Hawaii’s installment loans law. The law requires the daily proration of maintenance fees for any fraction of a month, allows lenders to charge a $1 convenience fee for accepting debit card payments, and removes the requirement that a lender must wait three days after full repayment to open a new installment loan with the same consumer—amongst other provisions. Effective July 1, 2025.

MAINE

LD 68 amends Maine’s tax laws by modifying the watercraft sales tax exemption to not apply to the lease or rental of a watercraft to a nonresident, clarifying the definition of motor vehicle “sales sourced to tribal land”, and specifying the type of property subject to casual rental taxation—amongst other provisions. Effective 90 days after adjournment.

LD 850 amends current motor vehicle laws in Maine. The bill adds a $1 fee for electronic lien titling transactions, raises the temporary plate fee from $1 to $2, and allows the Secretary of State to adopt new rules in regards to an electronic temporary registration plate program. Effective January 1, 2026.

MARYLAND

HB 352 adjusts many of the registration and title fees for vehicles, increases the Motor Vehicle Excise Tax rate for rental and non-rental vehicles, and clarifies the process around vehicle registration renewals. Effective July 1, 2025.

MINNESOTA

HF 14 is the State of Minnesota’s Transportation Appropriations bill for fiscal years 2026-2027. Amongst a host of other provisions, this bill allows motor vehicle dealers licensed under contiguous states to be a Minnesota licensed dealer for certain activities. In addition, the bill modifies the surcharge for electric vehicles and establishes a surcharge for plug-in hybrid vehicles to both be based on vehicle price and age with base minimum fees. Effective dates begin immediately for certain provisions, while others are effective October 1, 2025, or January 1, 2026.

NEBRASKA

LB 474 combines Nebraska’s Installment Sales Act and its Installment Loan Act. The new law—the Nebraska Installment Loan and Sales Act—does not change core substantive provisions applicable to retail installment sales or loans. Effective three calendar months after adjournment.

NEVADA

Signed into law on June 11, 2025, AB 296 concerns itself with two items: the adoption of digital license plates and the Department of Motor Vehicles’ implementation of this policy, and the use of lenders to offer installment loans to vehicle owners to pay for motor vehicle registration fees and taxes through a Department-affiliated website. Such lenders are not allowed to charge more than fifteen percent of the amount financed and the amount financed must be $250 or more. Effective immediately.

SB 437 allows an internet consumer lender without a physical address within Nevada to apply for a Nevada lending license. Additionally, the bill requires internet consumer lenders to apply Nevada law to Nevadan borrowers and resolve any dispute in state. Effective October 1, 2025.

OREGON

HB 3875 will now apply the Oregon Consumer Privacy Act to motor vehicle manufacturers and affiliates. This bill applies the Privacy Act to any party that controls or processes personal data from a consumer’s use of a motor vehicle or motor vehicle component. Effective on the 91st day following adjournment sine die.

SB 430 requires that any person who offers or sells goods or services online to display the total cost in any advertisement, display, or offer, except for any governmental taxes or fees, shipping costs, or service fee. Effective January 1, 2026.

WASHINGTON

SB 5801 is a lengthy Transportation Bill which was signed into law on May 5, 2025. The bill increases fees in a number of categories, including titling and registering a vehicle, title filing, and replacement tires. In addition, the bill increases the motor vehicles sales and use tax, the rental car tax, and creates a new luxury vehicle tax on certain vehicles exceeding $100,000. Effective July 1, 2025, in part.

CORRECTION

TEXAS

Alternate Consumer Loans Subchapter F – §§342.251 – 342.252

Loan Amount Acquisition Charge plus Installment Acct Handling Charge
Under $30: 12.5% cash advance
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 $900: 12.5% cash advance, up to $125 plus $4 per month for each $100
From $900.01 up to $1,800: 12.5% cash advance, up to $125 plus $4 per month for each $100

Effective July 1, 2025.

May 2025 Compliance Updates

Effective State Changes

ARKANSAS

HB 1845 authorizes the Arkansas Department of Finance and Administration to work in coordination with the Office of Motor Vehicle to establish an electronic lien, title, and registration system. Effective upon certification of the electronic system by the Office of Motor Vehicle.

FLORIDA

The Florida Department of Financial Services has amended three rules regarding Deferred Presentment transaction repayments (69V-560.903, 69V-560.905, and 69V-560.908), specifically to allow payments made by debit cards and prohibit payments using credit cards. Effective May 21, 2025.

INDIANA

HB 1382 provides that if certain persons engage in the buying, selling, or trading of a motor vehicle on a Sunday, it is considered a Class B misdemeanor, amongst other provisions. Effective July 1, 2025.

SB 73 amends definitions governing unfair practices and succession eligibility for franchise dealers’ family members. Additionally, the bill changes certain requirements for dealers who only sell trailers. Effective July 1, 2025.

MARYLAND

The Maryland Department of Transportation amended and adopted new regulations requiring owners of an eligible plug-in electric vehicle to pay an annual surcharge in addition to a registration fee. COMAR 11.15.40.05.B.  makes that surcharge subject to annual adjustment using the Consumer Price Index – Urban, rounded to the nearest whole dollar. Effective May 26, 2025.

HB 1046 prohibits a mechanical repair contract from implementing terms that preclude coverage if a technical service bulletin has announced a motor vehicle issue. The bill also prohibits the denial of a service claim for such an issue. Effective October 1, 2025.

HB 1464 creates an alternative registration process for rental fleet vehicles and mandates a distinctive registration plate and a one-time fee for vehicles registered through this alternative process. Effective October 1, 2025.

MONTANA

Governor Gianforte signed HB 114 on May 1, 2025. The bill amends the law to allow a person or depository institution to inform consumers that insurance is required to obtain a loan or credit, that approval for such a loan or credit is contingent on having acceptable insurance, and that the person or depository institution has insurance available for such a transaction. Effective January 1, 2026.

SB 341 changes the definition of motor vehicle to include recreational vehicles and allows dealers selling recreational vehicles, boats, or powersport vehicles to advertise and sell such vehicles outside of the county of the primary place of business. Effective October 1, 2025.

NEBRASKA

Following trends seen around the country, LB 667 is Nebraska’s attempt to reform the compensation franchisors pay new motor vehicle dealers for diagnostic work performed and parts supplied during warranty repairs. Effective September 9, 2025.

NEW JERSEY

SB 3525 will now allow mortgagors to make biweekly and semi-monthly payments, as well as payments to pay-down a mortgage principal without a penalty. Effective six months following enactment.

NEW MEXICO

As published in Bulletin 2025-002 in May 2025, the New Mexico Insurance Commissioner adjusted the prima facie credit insurance rates effective July 1, 2025.

Credit life prima facie rates will stay the same:

  • Monthly outstanding balance (rates per $1,000 per month):
    • Single Decreasing Life: $0.39
    • Joint Decreasing Life: $0.57
  • Single Premium (rates per $100 per annum):
    • Single Decreasing Life: $0.25
    • Joint Decreasing Life: $0.36
    • Single Level Life: $0.45
    • Joint Level Life: $0.67

The A&H rates will decrease. The 12-month rate per $100 of Initial Insured Indebtedness will be as follows:

  • 14 Retro:   $0.63
  • 14 Elim:     $0.52
  • 30 Retro:  $0.50
  • 30 Elim:    $0.40

Effective July 1, 2025.

OKLAHOMA

Governor Kevin Stitt signed SB 377 into law on April 28, 2025. The bill regulates business activities between equipment suppliers and their dealers. Amongst other prohibitions, suppliers are prevented from requiring dealers to only sell certain brands or have separate facilities for different brands. Effective November 1, 2025.

OREGON

Another bill following trends seen around the country, HB 2127 seeks to establish clearer rules regarding acceptable business practices between motor vehicle manufacturers, their affiliates, and vehicle dealers. These new requirements run the gamut from compensation for warranty work performed by vehicle dealers, to proper allocation of new vehicles for sale, to construction of dealership infrastructure. Effective January 1, 2026.

HB 3178 requires a dealer in a motor vehicle transaction involving a retail or lease agreement to provide a consumer with a disclosure document that includes a right to void the transaction within ten calendar days. Additionally, this bill requires the Attorney General to provide a model contract form with translations in five different languages. Finally, this bill details specific actions a dealer must take in order to void a transaction. Effective January 1, 2026.

VIRGINIA

SB 1212 and identical bill HB 2515 prohibit a supplier from advertising or displaying a price for goods or services without clearly and conspicuously displaying the total price, including all mandatory fees or surcharges. However, an exemption exists for fees relating to the purchase or lease of a motor vehicle. Effective July 1, 2025.

WASHINGTON

HB 1006 modifies financial responsibility provisions for motor vehicle protection product guarantee providers and service contract providers and requires reimbursement insurance policies used by these providers to pay or provide services to consumers directly within 30 days in the instance of nonperformance. Effective July 27, 2025.

WEST VIRGINIA

HB 3089 mandates all financial institutions, vehicle dealers, or anyone recording five or more liens within a calendar year to use the state’s electronic lien and title system. Additionally, no paper title will be issued to a lienholder after the full adoption of the electronic system. Effective July 1, 2025.

Reminders

MINNESOTA

Passed in 2023, HF 2887 increases the maximum Documentary fee to the lesser of $350 or an amount equal to ten percent of the value of the sale or lease. Effective July 1, 2025.

MISSISSIPPI

Mississippi Senate Bill 2495 updates the Mississippi Credit Availability Act. Effective July 1, 2025.

OKLAHOMA

The Department of Consumer Credit published the changes in dollar brackets for Retail Installment Sales and Consumer Loans. Effective July 1, 2025.

TENNESSEE

SB 694 impacts the state’s Industrial Loan and Thrift Companies Act’s rate structure. Effective July 1, 2025.

TEXAS

The Texas Office of Consumer Credit Commissioner published dollar amount brackets and ceilings subject to adjustment in the Texas Financial Code for Retail Installment Sales and Consumer Loans. Effective July 1, 2025.

April 2025 Compliance Updates

Effective State Changes

FLORIDA

Regulations 69V-160.030 through 69V-160.111 were amended by redefining where a consumer finance company’s “principal place of business” is located and providing clarity on the forms and processes for reporting to the state. Effective March 11, 2025.

ILLINOIS

The Illinois Secretary of State amended 92 Ill. Adm. Code 1010 to address the fee charged by Electronic Lien and Title (ELT) System Service Providers and the qualifications and procedures to be enrolled as a Service Provider. Additionally, the rules provide for the suspension and termination of a Service Provider from the ELT Program. Effective January 25, 2025.

INDIANA

SB 484 codifies the practices of RV manufacturers, distributors, and dealers and allows the sale of RVs on Sundays as part of a recreational vehicle show under a special event permit. Effective July 1, 2025.

As published in Bulletin 277 in December 2024, the Indiana Insurance Commissioner adjusted credit insurance rates effective January 1, 2025. The discount rate used for credit life is 3.47%. The discount rate used for accident and health (A&H) is 3.07%.

Credit life prima facie rates for monthly outstanding balance are increased to:

  • $1.07 per month per $1,000 of outstanding insured debt on single life
  • $1.79 per month per $1,000 of outstanding insured debt on joint life

The A&H rates will decrease. The 12-month rate per $100 of Initial Insured Indebtedness will be as follows:

  • 14 Retro:   $1.41
  • 14 Elim:     $0.99
  • 30 Retro:  $0.97
  • 30 Elim:    $0.72

Effective January 1, 2025.

IOWA

ARC 8727C is a regulation promulgated by the Revenue Department of Iowa clarifying the one-time fee due for a new registration of a motor vehicle. Effective April 23, 2025.

KANSAS

HB 2122 increases the annual license fees for electric vehicles and plug-in electric hybrids. It also imposes new fees on electric motorcycles, as well as trucks and truck tractors that are electric or hybrid with gross weights of 12,000 pounds or less. Effective January 1, 2026.

KENTUCKY

SB 136 requires the Kentucky Transportation Cabinet to transition to solely store motor vehicle titles electronically—but allows title holders to request a physical copy. Additionally, the electronic system will now be used for liens, temporary tags, and boat transfers. Effective, in part July 1, 2025.

SB 145 allows the holder of a motor vehicle retail installment contract to collect a delinquency charge for a late payment after 3 days if the installment period is less than 28 days, or after 10 days for installment periods of 28 days or more. The bill also allows the holder of a retail installment contract for consumer goods other than motor vehicles to collect a delinquency charge of 5% of the installment or $15, whichever is greater, on each installment in default for more than 10 days. Effective 90 days after the close of the legislative session.

MISSISSIPPI

Mississippi Senate Bill 2495 was signed by the Governor on March 12, 2025. The Bill updates the Mississippi Credit Availability Act (MCAA), extending the sunset date to July 1, 2030. The maximum allowable outstanding principal balance for credit availability accounts has been raised from $2,500 to $3,250. Beginning in 2025, the Mississippi Department of Banking and Consumer Finance will adjust the maximum loan amount based on the CPI-U. Effective July 1, 2025.

MONTANA

On April 3, 2025, HB 99 was signed into law by Governor Greg Gianforte. The bill consolidates the definitions of several different boating vessels and clarifies the temporary registration periods for certain vehicles, amongst other provisions. Effective October 1, 2025.

HB 165 removes the need for a notarized affidavit to transfer a vehicle title in Montana. Effective October 1, 2025.

NEBRASKA

LB 97 raises the cost of license plates. Effective April 14, 2025.

Published in Guidance Document IGD – A2 in January of 2025, the Nebraska Department of Insurance adjusted credit life rates effective April 1, 2025 – January 1, 2026. Rate adjustments for 2026 and 2027 are also included in the bulletin.

Credit life prima facie rates are:

  • Single Premium Decreasing Term Life: $0.45 per year per $100 indebtedness
  • Joint Life: $0.76 per year per $100 indebtedness
  • Outstanding Balance Life: $0.62 per $1,000 per month on the outstanding balance
  • Joint Life: $1.04 per $1,000 per month on the outstanding balance
  • Level Term Life: $0.83 per year per $100 original indebtedness
  • Joint Life: $1.39 per year per $100 original indebtedness

The A&H rates for the 12-month rate per $100 of Initial Insured Indebtedness will be as follows:

  • 14 Retro:  $1.33
  • 14 Elim:    $0.90
  • 30 Retro: $0.90
  • 30 Elim:   $0.49
  • Joint A&H are based on a factor of 1.80.

Effective April 1, 2025.

NORTH DAKOTA

HB 1127 creates new data security requirements for non-depository financial corporations and adds the definition of a “loan,” specifying it includes alternative financing products as identified by the Commissioner of the Department of Financial Institutions. Effective August 1, 2025.

Following trends seen around the country, HB 1515 amends the laws regarding warranty work compensation that must be paid by manufacturers and distributors to motor vehicle dealers for labor and parts. Effective August 1, 2025.

SOUTH DAKOTA

SB 131 creates a new electronic title and lien system to be administered by the South Dakota Department of Revenue. Effective July 1, 2025.

TENNESSEE

On March 25, 2025, Tennessee Governor Bill Lee signed Senate Bill 694 into law, modifying the state’s Industrial Loan and Thrift Companies Act rate structure. The bill increases the maximum effective interest rate from 30% to 36% of the principal for loans with an amount financed of $100 or more. In addition, as an alternative to loan charges and interest allowed under the Act for loans of $100 up to $2,000, the maximum permitted acquisition charge is increased from 10% to 12.5% of the principal. Effective July 1, 2025.

TEXAS

Released in February 2025, the dollar amount brackets and ceilings subject to adjustment in the Texas Finance Code will increase as follows:

Consumer Loans – §342.201

(Add-On Rates)

$18 per $100 per annum of the cash advance to $2,700 plus,

$8 per $100 per annum of the excess to $22,500

OR

(Simple Melded Rates)

30% per annum of the cash advance to $4,500 plus,

24% of the excess to $9,450 plus,

18% of the remainder to $22,500

Alternate Consumer Loans Subchapter F – §342.251

Loan Amount Acquisition Charge plus Installment Acct Handling Charge
Under $30: $1 for each $5 cash advanced
From $30 up to $35: 10% cash advance plus $3 per month
From $35.01 up to $70: 10% cash advance plus $3.50 per month
From $70.01 up to $100: 10% cash advance plus $4 per month
From $100.01 up to $900: $10 plus $4 per month for each $100 of the cash advance
From $900.01 up to $1,800: $10 plus $4 per month for each $100 of the cash advance

Retail Installment Sales (“Other Goods”) – §345.055

(Add-On Rates)

$12 per $100 per annum of the principal balance to $4,500 plus,

$10 per $100 per annum of the excess to $9,000 plus,

$8 per $100 per annum of the remainder.

Effective July 1, 2025.

UTAH

HB 272 increases the maximum Gross Vehicle Weight Rating from 12,000 lbs. to 14,000 lbs., for the purposes of registering a vehicle in the state and paying a uniform fee rather than a vehicle age-based fee. Effective July 1, 2025.

HB 514 allows two-year registrations for trailers, off-highway vehicles, street-legal all-terrain vehicles, and electric motor vehicles, amongst other provisions. Effective January 1, 2026.

SB 27 defines terms in the law for trailers, motorboats, and motorcycles, allows a fleet of personal vehicles to be registered as a fleet, and clarifies which registration fees apply to certain vehicles. Effective in part on May 7, 2025.

VIRGINIA

HB 1683 and identical bill SB 1308 follow trends seen nationwide related to manufacturers’ and distributors’ reimbursement to motor vehicle dealers for costs related to vehicle recalls and warranties, amongst other provisions. Effective July 1, 2025.

HB 2659 allows dealers to use separate buyer’s orders forms for leases and sales of motor vehicles. Effective July 1, 2025.

Rate Adjustments for Consumer Loans in Mississippi & Tennessee

FOR IMMEDIATE RELEASE

For more information contact:
Carleton Sales Team
574.243.6040 option #3
sales@carletoninc.com

Mississippi

Mississippi Senate Bill 2495 was signed by the Governor on March 12, 2025. The Bill updates the Mississippi Credit Availability Act (MCAA). Key provisions in the bill include:

  • Extended Repeal Date: The sunset provision of the MCAA has been extended from July 1, 2026, to July 1, 2030.
  • Increase in Maximum Loan Amount: The maximum allowable outstanding principal balance for credit availability accounts has been raised from $2,500 to $3,250.
  • Annual Adjustment Based on CPI-U: Beginning in 2025, the Mississippi Department of Banking and Consumer Finance is mandated to issue an annual memo adjusting the maximum loan amount, by applying the Consumer Price Index for All Urban Consumers (CPI-U) for the previous calendar year to the previous year’s maximum, rounding up to the nearest $10 increment.

Effective July 1, 2025.

Tennessee

On March 25, 2025, Tennessee Governor Bill Lee signed Senate Bill 694 into law, modifying the state’s Industrial Loan and Thrift Companies Act (“the Act”) rate structure. The bill increases the maximum effective interest rate from 30% to 36% of the principal, for loans with an amount financed of $100 or more. In addition, as an alternative to loan charges and interest allowed under the Act for loans of $100 up to $2,000, the maximum permitted acquisition charge is increased from 10% to 12.5% of the principal.

Effective July 1, 2025.

 

If you are a Carleton partner and would like additional information or would like to request a file update, please submit a case in the Carleton Customer Portal.

 

About Carleton, Inc.:

Carleton is the country’s leading provider of financial calculation software, loan origination compliance support, and document generation software. With over 55 years of experience, our ongoing expertise and industry knowledge reaffirms why Carleton is a trusted partner. Founded in conjunction with the Truth In Lending Act, Carleton provides expert compliance support with continuous accuracy in all our calculations and disclosures at a state and federal level. To learn more about Carleton’s lending solutions, contact our sales team at sales@carletoninc.com or 574-243-6040 option #3.

March 2025 Compliance Updates

Effective State Changes

ARKANSAS

Senate Bill 94 removes the requirement that a new all-terrain vehicle dealer must have a dedicated service and parts structure or perform repair or warranty work at their licensed location. However, the bill now requires that new all-terrain vehicle dealers must service the vehicles or provide for a service provider or warranty service provider for all-terrain vehicles within forty miles of the dealer’s location. Effective 90 days after sine die adjournment.

NEW YORK

Assembly Bill 920 adds medical and health insurance information to the definition of personal identifying information for certain statutory categories. Effective February 14, 2025.

OKLAHOMA

The Department of Consumer Credit published the changes in dollar amounts which will become effective July 1, 2025. Included in the adjustments are the following:

Retail Installment Sales, §2-201:

The greater of:

30% of the amount financed up to $1,980; plus

21% of the excess to $6,600; plus

15% of the remainder to $71,900.

OR  21% Simple Interest

The dollar amounts under §3-508(A) remain the same. The allowable closing fee increases from $184.64 to $190.41.

For loans subject to §3-508B of the Oklahoma Code, the maximum charge structure is:

Loan Amount Acquisition Charge Handling Charge
Up to $197.57 $6.59 per $32.94 of principal
$197.58-$230.58 1/10 of the amount of principal $19.76 per month
$230.59-$461.16 1/10 of the amount of principal $23.06 per month
$461.17-$658.80 1/10 of the amount of principal $26.35 per month
$658.81-$988.20 1/10 of the amount of principal $29.65 per month
$988.21-$1,317.60 1/10 of the amount of principal $32.94 per month
$1,317.61-$1,647.00 1/10 of the amount of principal $36.23 per month
$1,647.01-$1,976.40 1/10 of the amount of principal $39.53 per month
$1,976.41-$2,440.00 1/10 of the amount of principal $48.80 per month
$2,440.01-$3,050.00 1/10 of the amount of principal $61.00 per month
$3,050.01-$3,660.00 1/10 of the amount of principal $73.20 per month

The maximum delinquency charge for consumer credit sales and consumer loans will increase from $32.00 to $33.00. Effective July 1, 2025.

SOUTH DAKOTA

Senate Bill 135 will charge the owner of a motor vehicle, off-road vehicle, or snowmobile who does not have a state issued driver’s license, id card, or physical address in state, a $100 fee to title the vehicle in South Dakota, in addition to the title application fee. Effective July 1, 2025.

Senate Bill 179 allows a licensed vehicle dealer to apply for a permit to sell or offer to sell an off-road vehicle at an event located outside of the county where their principal place of business is located.  The event may not be longer than seven days, the dealer has to be a franchise dealer for off-road vehicles, and there must be no other franchise dealer in the county where the event takes place. Effective July 1, 2025.

WYOMING

House Bill 242 would require vehicle dealers who sell trailers to submit a sales authorization agreement to the state, amongst other provisions. Effective July 1, 2025.

Senate File 25 tasks the Department of Transportation with creating and maintaining an electronic lien and title system for the state of Wyoming. Effective July 1, 2027.

Senate File 39 provides for the automatic transfer of a vehicle title upon the death of the owner to a named beneficiary. Effective July 1, 2025.

Senate File 106 authorizes new vehicle dealers to establish hourly labor rates and retail parts markup rates to be charged for warranty repairs. Effective July 1, 2025.

February 2025 Compliance Updates

Effective State Changes

MICHIGAN

Michigan updated their Documentary Preparation Fee for 2025 through 2026. The fee cannot exceed the lesser of $280 or 5% of the cash price of the vehicle. Effective January 28, 2025.

MISSOURI

Missouri increased their Administrative Fee for 2025 to $604.47. Effective February 1, 2025.

NEW YORK

Senate Bill 804 was signed into law on February 14, 2025. The new law amends the current business law as to when and how data breach notifications must be provided to the Department of Financial Services. Effective immediately.

PENNSYLVANIA

Pennsylvania increased the maximum Documentary Preparation Charge for 2025 to either $398 or $477, with the larger amount applying to dealers that file documents electronically. Effective January 1, 2025.

2024 Year in Review – Compliance Updates

Review of State Changes Effective in 2024

ALASKA

  • HB 233 makes changes to the auto warranty statute by adding time allowances to the schedule of compensation for dealers’ warranty work. Effective October 27, 2024.

COLORADO

  • HB 1089 tasks the state to create an electronic communication system for vehicle owners for registration and license plates. Effective June 3, 2024.
  • SB 192 revamps Colorado’s Lemon Law for new vehicles. Effective August 7, 2024.

DELAWARE

  • Senate Substitute No. 2 for SB 278 creates new protections for motor vehicle franchise dealers in the state of Delaware. Effective August 29, 2024.

FLORIDA

  • HB 1347 changes the bracketed rate structures and tiers of the Consumer Finance Act, covering loans up to $25,000. Effective July 1, 2024.
  • SB 902 created the Florida Vehicle Value Protection Agreements Act. Effective October 1, 2024.

GEORGIA

  • HB 1100 authorizes the use of electronic notifications by the state regarding motor vehicle insurance coverage and title status. Effective April 22, 2024.

ILLINOIS

  • The document preparation fee in the State of Illinois increased to $358.03 for 2024. Effective January 1, 2024.

INDIANA

  • The Indiana Secretary of State increased the allowable Documentation Preparation Fee to $245.28 up from $237.51. Effective July 1, 2024.

IOWA

  • HF 2185 mandates that the certificate of title for a motor vehicle will no longer include the previous owner’s name and address. Effective July 1, 2024.
  • SF 2362 prohibits the sale of service contracts in Iowa unless certain provisions are met. Effective July 1, 2024.

KANSAS

  • HB 2098 allows the purchaser of a new or used vehicle a sales tax deduction due to the recent sale of another vehicle. Effective July 1, 2024.
  • SB 345 creates the Commercial Financing Disclosure Act requiring the disclosure of certain commercial financing transaction terms. Effective July 1, 2024.

LOUISIANA

  • SB 372 eliminates the registration and renewal fees for providers of motor vehicle service contracts. Effective August 1, 2024.

MAINE

  • LD 2072 requires the state to provide a printed certificate of title, if requested, by a lienholder participating in the electronic lien titling system. Effective August 9, 2024.

MARYLAND

  • HB 352 and SB 362 raised the annual vehicle registration fees and the maximum dealer processing charge (or doc fee) from $500 to $800. Effective June 1, 2024.

MICHIGAN

  • HB 5460 allows a retail installment sales contract for a vehicle to provide for a series of monthly payments in unequal payment amounts. Effective July 23, 2024.
  • Bulletin 2024-05-CF stated that the loan processing fee amount will remain at $400 through December 31, 2025. Effective January 1, 2024.
  • SB 533 allows the state to issue an electronic vehicle title and establish an electronic system to facilitate vehicle ownership transfers. Effective February 13, 2024.

MINNESOTA

  • HF 2887 increases the maximum Documentary fee to the lesser of $275 or an amount equal to ten percent of the value of the sale or lease. Effective July 1, 2024.
  • The Minnesota Commerce Department published the periodic adjustment in dollar amounts effective through June 30, 2026. Effective July 1, 2024.

MISSISSIPPI

  • SB 2543 increased the maximum amount to $5,100 for loans permitted under the Mississippi Consumer Alternative Installment Loan Act. Effective July 1, 2024.

MISSOURI

  • The document preparation fee in Missouri was increased through emergency rulemaking from $565.38 to $587.43 for 2024. Effective February 23, 2024.

NEBRASKA

  • LB 1317 creates a $150 registration fee for a vehicle powered by an alternative fuel and a $75 fee for a motorcycle or plug-in hybrid. Effective April 25, 2024.

NEW HAMPSHIRE

  • HB 1243 replaced the Retail Installment Sales of Motor Vehicles Chapter, significantly changing existing law. Effective July 1, 2024, in part, and September 1, 2024.

NEW JERSEY

  • AB 4702 phases out the sales and use tax exemption on zero-emission vehicles. Effective June 28, 2024.
  • AB 4011 amends the Transportation Trust Fund Authority Act imposing a $250 fee for any zero-emission vehicle registered in the state. Effective July 1, 2024.
  • SB 4084 requires new procedures for the issuing of temporary license plates and registration certificates in New Jersey. Effective August 1, 2024.

NEW YORK

  • AB 4066 establishes vehicle manufacturers must pay reasonable compensation to franchise dealers for warranty work. Effective September 4, 2024.

OHIO

  • SB 94 establishes processes for releasing electronic liens once a security interest is discharged. Effective October 24, 2024.

OKLAHOMA

  • The Department of Consumer Credit published adjustments to allowable charges for retail installment contracts and small loans. Effective July 1, 2024.

SOUTH CAROLINA

  • The Department of Consumer Affairs released its biannual dollar bracket adjustment effective through June 30, 2026. Effective July 1, 2024.
  • The South Carolina Department of Insurance adopted orders confirming Prima Facie Credit A&H and Credit Property insurance rates. Effective January 1, 2024.
  • SB 434 prohibits automatic service contract renewals unless the provider notifies the contract holder within a certain timeframe. Effective May 20, 2024.

SOUTH DAKOTA

  • HB 1063 requires county treasurers to collect evidence of sales or other tax paid to another state at the time of vehicle registration. Effective July 1, 2024.
  • SB 112 allows any non-resident owner to title a motor vehicle, off-road vehicle, snowmobile, or boat in South Dakota by paying a $100 fee. Effective July 1, 2024.

TENNESSEE

  • HB 2075 and companion bill SB 1837 creates a new statewide electronic lien and title system to be implemented by December 31, 2025. Effective May 1, 2024.
  • SB 1140 allows motor vehicle dealers to retain 2% of the first $2,500 and 1.15% on anything above $2,500 of sales taxes due to the state. Effective May 28, 2024.

TEXAS

  • The Texas OCCC published dollar brackets and ceilings subject to adjustment for Retail Installment Sales and Consumer Loans. Effective July 1, 2024.
  • The OCCC released TRD-202403782 and TRD-202405041 revising regulations for vehicle sales financing and vehicle installment sales. Effective November 14, 2024.
  • The OCCC updated the documentary fee for a motorcycle, moped, ATV, boat, boat motor, boat trailer, or towable recreational vehicle. Effective September 5, 2024.
  • The OCCC updated the Acquisition Charge for Small Loans (Subchapter F) and the Administrative Fee and Large Loans (Subchapter E). Effective July 11, 2024.
  • HB 2746 amended the Texas Finance Code regarding refunds for the termination of a debt cancelation agreement upon prepayment. Effective January 4, 2024.

UTAH

  • HB 174 requires a person who provides a product or service with an automatic renewal provision to provide notice prior to the renewal date. Effective, in part, May 5, 2024.

VIRGINIA

  • HB 744 adds new consumer protections to Virginia law regarding the automatic renewal of service offers. Effective July 1, 2024.
  • HB 1106/SB 452 directs independent vehicle dealers to pass a DMV examination which costs $50 in order to renew a dealership license. Effective July 1, 2024.

WEST VIRGINIA

  • The Motor Vehicle Dealers’ Advisory Board approved an increase in the maximum Documentary Fee from $499 to $575. Effective July 1, 2024.

Review of State Changes Effective in 2025 and Beyond

CALIFORNIA

  • AB 1755 streamlines the civil process for lemon law disputes. Effective January 1, 2025.
  • SB 1521 allows certain fees for commercial financing if properly disclosed. Effective January 1, 2025.
  • SB 1096 requires certain language be disclosed in at least 16-point bold font on the front of an envelope soliciting consumer financial information. Effective January 1, 2025.

HAWAII

  • SB 1534 replaces the current $50 registration fee for electric vehicles with a mileage-based usage charge, beginning July 1, 2025.

ILLINOIS

  • The document preparation fee in the State of Illinois increased to $367.70. Effective January 1, 2025.

IOWA

  • HF 674 allows any county treasurer to issue certificates of title, registrations, and perfect security interests outside of their county. Effective January 1, 2025.

KANSAS

  • HB 2247 changes the threshold amount and rates for consumer loans and retail installment sales, amongst a host of other provisions. Effective January 1, 2025.

KENTUCKY

  • HB 8 removes the $60 ownership fee for hybrid vehicles that do not have plug-in charging capability in the state of Kentucky. Effective January 1, 2025.

MISSISSIPPI

  • HB 1589 provides that a lienholder must electronically transmit to the Department of Revenue within 14 days of release of the lien. Effective January 1, 2025.

SOUTH CAROLINA

  • The South Carolina Department of Insurance adopted orders confirming Prima Facie Credit A&H and Credit Property insurance rates. Effective January 1, 2025.

VERMONT

  • HB 546 allows a sales tax deduction for the previous sale of another ATV, as long as it was sold within 3 months of the purchase of a new ATV. Effective January 1, 2025.

VIRGINIA

  • The Order Adopting Adjusted Prima Facie Rates for the Triennium Commencing January 1, 2025, enacts insurance rates for the next 3 years. Effective January 1, 2025.

WISCONSIN

  • SB 668 overhauled the Department of Financial Institutions’ oversight of non-mortgage licensed financial service providers. Effective January 1, 2025.

Review of Federal Changes Effective in 2024

CONSUMER FINANCIAL PROTECTION BUREAU

  • Dollar threshold adjustments were announced for the Ability to Repay/ Qualified Mortgage Rule and HOEPA. Effective January 1, 2024.
  • The CFPB increased TILA threshold adjustments for Regulation M and Z from $66,400 to $69,500. Effective January 1, 2024.
  • The CFPB released a final rule to decrease the late fee “safe harbor” amount for larger card issuers from $30 to $8. Due to pending litigation, the rule is on hold.

FEDERAL TRADE COMMISSION

  • The FTC issued CARS Rule on December 12, 2023, with an effective date of July 30, 2024. Due to pending litigation, the rule is on hold.

Review of Federal Changes Effective in 2025

CONSUMER FINANCIAL PROTECTION BUREAU

  • The CFPB increased TILA threshold adjustments for Regulation M and Z from $69,500 to $71,900. Effective January 1, 2025.
  • Dollar threshold adjustments were announced for the Ability to Repay/ Qualified Mortgage Rule and HOEPA. Effective January 1, 2025.

December 2024 Compliance Updates

Effective State Changes

INDIANA

Indiana published LSA Document #24-266, which implements certain bracket updates, including:

  • The graduate rate thresholds for sales and loans increase to $2,600/$5,200, respectively.
  • The minimum credit service charge increases to $63.00.
  • The delinquency charge for sales and loans increases to $21.50.
  • The minimum finance charge for loans increases to $63.00.
  • The maximum loan term is 37 months for loans with principals of $1,290 to $5,200.

Effective January 1, 2025 – December 31, 2026.

PENNSYLVANIA

Pennsylvania added motorcycles to the protections afforded by its existing Lemon Law in SB 155. Effective May 18, 2025.

NEW YORK

Assembly Bill 3499 clarifies and creates new laws surrounding automobile broker businesses, including requiring additional disclosures to consumers seeking to purchase or lease automobiles with the assistance of an automobile broker. Effective June 19, 2025.

Signed into law on December 21, 2024, Assembly Bill 8913 directs the superintendent of financial services to create a publicly accessible private education debt registry in New York. Any private education creditor must register with the superintendent and satisfy a host of annual reporting requirements, for use by the registry. Effective immediately.