Compliance Alerts

September 2026 Compliance Updates

September 2026 Compliance Updates

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.

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