# FTC CARS Rule Vacated: What Still Applies to BHPH GPS > The FTC's CARS Rule never took effect and was withdrawn in February 2026. What that means for GPS on financed cars, and which rules still apply. Canonical: https://gpsleaders.com/blog/ftc-cars-rule-bhph-gps-tracking-compliance Last updated: 2026-09-25 BHPH & Lender Tracking ## FTC CARS Rule Vacated: What Still Applies to BHPH GPS The FTC's CARS Rule never took effect and was withdrawn in February 2026. What that means for GPS on financed cars, and which rules still apply. By [Nick Muratore](https://gpsleaders.com/about) GPS Veteran & CEO, GPS Leaders·February 3, 2026·3 min read ![FTC CARS Rule & GPS Tracking Compliance for BHPH Dealers](https://gpsleaders.com/_emdash/api/media/file/763a7370d1bd40624579f9b9a932372e.jpg) ### Key takeaways - The FTC's CARS Rule (Combating Auto Retail Scams) never took effect. The FTC delayed it in February 2024 while dealer groups challenged it in court. - On January 27, 2025, the U.S. Court of Appeals for the Fifth Circuit vacated the rule because the FTC skipped a required step in its own rulemaking process. - On February 12, 2026, the FTC formally withdrew the rule in the Federal Register (91 FR 6507). - The FTC Act still prohibits unfair or deceptive practices, and state law still governs GPS devices and starter interrupt on financed vehicles. ### Is the FTC CARS Rule in effect? No. The FTC published the CARS Rule on January 4, 2024 (89 FR 590). On February 22, 2024, it delayed the rule's effective date while the National Automobile Dealers Association and the Texas Automobile Dealers Association challenged it in court. The rule never took effect, and it has now been withdrawn. ### Why did the court strike it down? The Fifth Circuit found that the FTC "violated its own regulations when it failed to issue an ANPRM," an advance notice of proposed rulemaking, and that the error was not harmless. The decision turned on how the rule was made. The court did not decide whether the rule's requirements were good policy. ### When did the FTC withdraw it? The FTC published the withdrawal in the Federal Register on February 12, 2026, effective the same day, to conform the rule with the Fifth Circuit's decision. The same notice also revised the FTC's Negative Option Rule and removed its Non-Compete Rule, both after court decisions. ### What does this mean for GPS on financed vehicles? The CARS Rule's specific requirements for add-on products do not apply, because the rule no longer exists. Other law still does. Section 5 of the FTC Act (15 U.S.C. § 45) prohibits unfair or deceptive acts or practices in commerce, and it applies whether or not the CARS Rule exists. ### What still applies to GPS and starter interrupt? - **Federal:** Section 5 of the FTC Act, which covers how any product, including a GPS device, is described and priced to a customer. - **State:** State law governs GPS devices and starter interrupt on financed vehicles, and the rules differ from state to state. Several states set specific rules for disabling a financed vehicle, so starter interrupt is used within your state's rules. - **Your contract:** the terms in your retail installment contract and any GPS disclosure the customer signs. ### What GPS Leaders offers for BHPH dealers Our BHPH / lender tracker is $89 per car with five years of service included and no annual fees, with an optional starter interrupt. See [BHPH tracking](https://gpsleaders.com/bhph-tracking). ### FAQ #### Is the CARS Rule coming back? The FTC withdrew it in February 2026 to match the court's decision. A new federal rule on auto retail would need a new rulemaking. #### Do I still have to disclose GPS to customers? The CARS Rule's requirements are gone, but the FTC Act and state laws still apply, and state rules vary. Check your state's rules with your attorney. #### Is starter interrupt legal? Dealers use it in many states, but several states have specific rules for disabling a financed vehicle. Use it within your state's rules. #### Did the court say dealers can charge for anything? No. The ruling was about the FTC's rulemaking process, and the FTC Act's ban on unfair or deceptive practices still applies. **Sources:** [Federal Register, 91 FR 6507 (Feb. 12, 2026)](https://www.federalregister.gov/documents/2026/02/12/2026-02866/revision-of-the-negative-option-rule-withdrawal-of-the-cars-rule-removal-of-the-non-compete-rule-to); *National Automobile Dealers Association v. FTC* (5th Cir., Jan. 27, 2025); [15 U.S.C. § 45](https://www.law.cornell.edu/uscode/text/15/45). *This is general information, not legal advice.* BHPH & Lender Tracking ### BHPH GPS tracking: $89, five years of service, paid once The hardwired tracker BHPH dealers and lenders buy from us: reports every two minutes, impound-lot notifications, top-stops reporting and the Repo Recovery App. No annual fees for five years, and a GPS Expert answers the phone. [See BHPH GPS tracking](https://gpsleaders.com/bhph-tracking/compare) [Request a quote](https://gpsleaders.com/request-a-quote?from=blog-post) [](https://gpsleaders.com/bhph-tracking/compare) The tracker for this #### BHPH / Lender Tracking Device 5-Year Service · No Annual Fees $89$109 Qty [See the page →](https://gpsleaders.com/bhph-tracking/compare) Most orders ship same day · US only · 3-year warranty Opt in #### Nick's notes, by email. One email when there's something worth knowing: a recovery that worked, a rule that changed, a number that surprised us. No drip campaigns. ![Nick Muratore](https://gpsleaders.com/team/nick-muratore-160.webp) [Nick Muratore](https://gpsleaders.com/about) GPS Veteran & CEO, GPS Leaders Nick Muratore is the founder and CEO of GPS Leaders, a vehicle intelligence company he established in 2015 and continues to lead from California. Over a 32-year career he has evaluated more than 120 GPS hardware and software products, developing the comparative expertise that underpins the company's approach: recommending systems on evidence of field performance rather than specification. Under his direction GPS Leaders serves vehicle finance, dealership, rental, fleet and equipment operators nationwide, on a model built around transparent pricing, no annual fees, and owner-level accountability. BHPH & Lender Tracking ### BHPH GPS tracking: $89, five years of service, paid once The hardwired tracker BHPH dealers and lenders buy from us: reports every two minutes, impound-lot notifications, top-stops reporting and the Repo Recovery App. No annual fees for five years, and a GPS Expert answers the phone. [See BHPH GPS tracking](https://gpsleaders.com/bhph-tracking/compare) [Talk to a GPS Expert →](https://gpsleaders.com/talk) [](https://gpsleaders.com/bhph-tracking/compare) While you read #### BHPH / Lender Tracking Device 5-Year Service · No Annual Fees $89$109 Qty [See the page →](https://gpsleaders.com/bhph-tracking/compare) Most orders ship same day · US only · 3-year warranty Opt in #### Get the next one before it's on the site. One email when there's something worth knowing: a recovery that worked, a rule that changed, a number that surprised us. Written by Nick, sent when it's ready. ### Keep reading · bhph & lender tracking [All articles →](https://gpsleaders.com/blog) [BHPH & Lender Tracking PassTime vs Spireon vs Trackhawk vs GPS Leaders (2026)](https://gpsleaders.com/blog/passtime-vs-spireon-vs-trackhawk-bhph-gps)[BHPH & Lender Tracking BHPH Tracking in Illinois](https://gpsleaders.com/blog/bhph-tracking-illinois)[BHPH & Lender Tracking BHPH Tracking in Colorado: GPS Solutions for Subprime Dealers](https://gpsleaders.com/blog/bhph-tracking-colorado-gps-solutions)[BHPH & Lender Tracking How GPS Tracking Improves Multi-Lot Inventory Control for BHPH Dealers](https://gpsleaders.com/blog/bhph-multi-lot-inventory-gps-tracking) Before you go ### Tell us what you finance, rent or run, and we'll tell you what to put in it. Your count, your current provider, and where the vehicles go. A GPS Expert answers with the tracker, the term, and the volume pricing. [Talk to a GPS Expert](https://gpsleaders.com/talk) [Compare the trackers](https://gpsleaders.com/bhph-tracking/compare)