300% Or Bust: The F&I Rule That Protects Your Dealership Now That Washington Isn't Coming to Save You

Direct Answer 

No single federal rule is coming to standardize F&I add-on disclosure for powersports, marine, and RV dealers — the FTC's CARS Rule is dead, and what's replacing it is a patchwork of state laws plus ongoing FTC enforcement under its existing authority. The most defensible position isn't waiting on Washington or your state legislature; it's running what we call the 300% Rule — present every product, to every customer, every single time — because a documented, consistent process is both the strongest compliance posture and the fastest path to meaningfully more F&I gross without selling a single extra unit. 

The Rescue Isn't Coming: What Actually Happened to the CARS Rule 

The Fifth Circuit killed the federal add-on disclosure rule dealers had been waiting on. On Jan. 27, 2025, the U.S. Court of Appeals vacated the FTC's Combating Auto Retail Scams (CARS) Rule in a 2-1 decision, ruling the agency had failed to follow required notice-and-comment procedures before adopting it. For a few years, dealers had a simple story to tell themselves about F&I compliance: a federal rule was coming, it would spell out exactly what disclosure and consent looked like, and once it landed everyone would comply with one clear standard. That story is over. 

The FTC did not appeal. By February 2026, the agency had formally withdrawn the rule. There is no indication a replacement federal rule is a near-term priority. If your compliance plan for add-on disclosure and menu consent was "wait for the CARS Rule," that plan no longer exists. 

Washington's Silence Doesn't Mean Safety — the FTC Is Still Punishing Dealers 

Losing the CARS Rule didn't take the FTC out of the game; it just means the agency is enforcing the same underlying problems through its existing authority under Section 5 of the FTC Act, which has prohibited unfair and deceptive practices for decades regardless of any specific auto rule. 

The clearest proof: in December 2024, the FTC and the Illinois Attorney General reached a proposed $20 million settlement with Leader Automotive Group and its parent company, AutoCanada — the largest monetary judgment the FTC has ever secured against an auto dealer. The complaint alleged that roughly 80% of surveyed Leader customers were charged for add-ons like protective coatings and theft-tracking devices they never agreed to, on top of undisclosed junk fees and inflated "certification" charges. The settlement requires clear offering-price disclosure and express, informed consent for every charge going forward. 

The FTC followed that with a broader signal in March 2026: warning letters to 97 auto dealer groups — more than 200 individual locations, including major public retailers like AutoNation, Lithia Motors, Group 1 Automotive, Hendrick Automotive Group, and Ken Garff Automotive Group — over advertised prices that didn't reflect the total amount a consumer would actually pay. None of this required a CARS Rule. It only required Section 5, which was never going anywhere. 

Separately, the FTC's Safeguards Rule remains in full force for any dealer who arranges financing — which, under the rule, makes a dealership a "financial institution" subject to data-security requirements including a written information security program, encryption, and breach notification, with fines that can reach $46,000 per violation, per day. 

States Are Writing Their Own Rules While Dealers Wait 

With federal rulemaking stalled, states aren't waiting. California's Senate Bill 766 — the state's own Combating Auto Retail Scams Act — has cleared the state Senate and carries a proposed effective date of Oct. 1, 2026. It would require clear disclosure of a vehicle's total price and prohibit charging for add-ons that provide the buyer no real benefit. 

Massachusetts moved even faster: the state Attorney General's "Junk Fee Rule" has applied to the advertising and sale of consumer products — new cars included — since Sept. 2, 2025, requiring the total price to be disclosed clearly and displayed more prominently than any other pricing figure. 

Neither of these is a powersports-specific law, and neither one has been tested yet against a motorcycle, UTV, or boat deal. But the direction is unmistakable: where Washington leaves a gap, states fill it with their own version of the same idea — clear, consistent, documented pricing and consent. A dealer selling in multiple states can't count on one rule; the only posture that works everywhere is a dealer's own consistent process, not a jurisdiction-by-jurisdiction guess. None of this is legal advice — talk to your own counsel about which of these rules, or a state-specific successor, actually applies to your stores. 

Quick Answers 

Is the FTC's CARS Rule still in effect? 

No. The Fifth Circuit vacated it on Jan. 27, 2025, and the FTC formally withdrew it in February 2026. There is currently no federal rule specifically governing auto add-on and junk-fee disclosure. 

Does this apply to powersports, marine, and RV dealers, or just car dealers? 

The specific FTC and state actions described here targeted auto dealers. But the underlying legal exposure — Section 5 of the FTC Act and the Safeguards Rule — applies to any dealer arranging financing, including powersports, marine, and RV dealers, regardless of vehicle type. 

What is ODL's "300% Rule"? 

It's One Dealer Lane's own name for a well-established F&I best practice — presenting every product, to every customer, every single time. It is not a law, a regulation, or a term used by regulators. 

Is this article legal advice? 

No. This is educational content, not legal advice. Dealers should confirm their own compliance obligations with their own attorney or compliance counsel. 

The 300% Rule: One Standard That Works Regardless of Which Law Applies 

None of the enforcement above happened because a menu tool was defective. It happened because the offer wasn't consistent — some customers got a product pitch, others didn't; some got a clear price, others got a number that grew after they sat down. That inconsistency is exactly what a regulator or a plaintiff's attorney goes looking for. 

The F&I industry has long had a name for the fix: 100% menu presentation — show every product to every customer, every time, instead of guessing who wants to hear about GAP coverage or a service contract. At ODL we call the full version of that discipline the 300% Rule: every product (100%), to every customer (100%), every single time (100%). To be clear, that's our own name for the practice, not a law, a regulation, or an official industry standard — but the underlying discipline is real, well-established, and exactly what regulators are effectively demanding when they penalize inconsistent, ad hoc disclosure. 

Run the 300% Rule and you get two things at once: a documented, defensible answer to "did you offer this to everyone, or just the customers you thought would say yes" — and, as the next section shows, meaningfully more F&I gross without touching your lead flow. 

The Math Nobody's Doing: Same Units, Triple the Profit 

Here's a simple, illustrative example — not a real dealer's numbers, just the arithmetic every store can run for itself. Say a dealership sells 30 units a month. That volume doesn't have to move at all for F&I profitability to change dramatically.

Thirty units at $200 in F&I PVR is $6,000 a month. The same 30 units at $600 — a realistic result of simply presenting every product to every customer, every time — is $18,000. Push execution to $1,000 PVR, which top-performing stores with a real process reach, and the same 30 units produce $30,000. Nobody sold a 31st unit. Nobody spent an extra dollar on leads. The difference is entirely process discipline and product penetration. 

That's the case for the 300% Rule in one sentence: you don't need more traffic or more inventory to be meaningfully more profitable — you need a menu that gets presented completely, consistently, and on the record, every single time. 

How Menu Lane Makes the 300% Rule Operational, Not Just Aspirational 

Saying "present every product to every customer every time" is easy. Proving it happened — on every deal, across every F&I manager, at every store — is the actual problem most dealer groups have never solved. That's the specific, narrow job Menu Lane is built to do inside the ODL platform. 

Because Menu Lane runs inside the same connected workflow as Sales Lane and Quick Lane, every deal opens the menu already knowing the vehicle, the trade, and the lender's actual approved terms — so there's no version of the menu that quietly skips a step because the desk didn't flag it. Every product presentation, every decline, and every consent is captured in the deal record automatically, which is what turns "we always offer everything" from a claim into something a dealer group can actually show a regulator, an auditor, or their own general manager. 

On the credit side, Quick Lane's consent and disclosure capture at intake reinforces the same discipline before the deal ever reaches the menu — the same documented, consistent trail Washington's own enforcement record shows regulators are looking for. 

Menu Lane isn't a compliance product bolted onto a sales tool, and it isn't a promise that a rule will never come for your dealership. It's the operational backbone that makes running the 300% Rule the path of least resistance instead of one more thing to remember on a busy Saturday.

About the Author 

Zac Jones is Head of Sales and Marketing at One Dealer Lane, where he works directly with dealer principals and F&I teams on the process discipline that separates a defensible, profitable F&I operation from one that's leaving money — and coverage — on the table. 

This article is general education, not legal advice. Consult your own attorney or compliance counsel about which federal, state, and local requirements apply to your dealership. 

Sources 

1. Nelson Mullins — "States Pick Up Stroke Regulating New Car Sales Practices Following FTC Loss on CARS Rule" (Aug. 26, 2025) 
2. Federal Trade Commission — "FTC, Illinois Take Action Against Leader Automotive Group for Overcharging and Deceiving Consumers Through Add-Ons, Junk Fees, Bogus Reviews" (Dec. 19, 2024) 
3. Federal Trade Commission — warning letters to 97 auto dealership groups on deceptive pricing (Mar. 13, 2026) 
4. Federal Trade Commission — "Automobile Dealers and the FTC's Safeguards Rule Frequently Asked Questions"