Dealer Markup of Interest Rates is an Unfair and Deceptive Practice
The Federal Trade Commission (FTC) Act makes unfair and deceptive acts and practices (UDAP) unlawful and empowers and directs the FTC to prevent such acts and practices through rule-making and enforcement. The Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") provided clear FTC jurisdiction over most auto dealers, particularly when entering into finance transactions with consumers, while freeing the FTC from the cumbersome procedural requirements that otherwise apply to FTC UDAP rule-makings. In easing these requirements, Congress signaled its intent that the FTC use...