Monday General Session

Jean Noonan

A Complete Review of the FTC CARS Rule

Monday General Session

The FTC plans to enact the CARS Rule, which will cause major disruptions for many dealers if it is enacted. This Rule will change the way you market and advertise vehicles and produce much more red tape for dealers. This Rule has faced criticism and is currently facing litigation. Opponents have expressed concerns about the rule’s complexity and negative impact on dealership operations and competitiveness. Jean will share the most up-to-date details about the brief that was filed on your behalf, as well as its implications and legal status. This is a must-attend session for all dealers.

Jean is a partner in the Washington, DC, office of law firm Hudson Cook. Jean advises clients on consumer financial services, fair lending, marketing, financial privacy, and consumer protection matters. She counsels financial institutions and others in complying with laws related to consumer credit, privacy, telemarketing, and unfair trade practices. 

Jean represents clients in government investigations, examinations, and enforcement actions before federal agencies, including the Consumer Financial Protection Bureau, Federal Trade Commission, and federal prudential regulators, and in other ancillary matters. 

Jean is a former executive with the Federal Trade Commission, where she directed the agency’s enforcement of consumer financial services laws. She also served for a decade as the General Counsel of the Farm Credit Administration, an independent federal bank regulatory agency. 

Jean has testified before Congress on legislative proposals relating to consumer financial services issues and lectures extensively on issues affecting financial institutions. 

Jean is actively involved in many associations, including the Consumer Financial Services Committee of the American Bar Association’s Business Law Section, where she has served as Chair, Federal and State Trade Practices Subcommittee; Vice-Chair, Privacy Subcommittee; and Chair, Federal Trade Commission Activities Subcommittee. Jean is a Founding Member of the American College of Consumer Financial Services Lawyers (ACCFSL), an organization limited to those lawyers who have achieved preeminence in the field of consumer financial services law; membership is by invitation only. She currently serves as President and has served as Treasurer, Secretary and Chair to the ACCFSL’s Lifetime Achievement Award Committee and the Writing Competition Committee. 

In January 2020, Jean was appointed to serve for one year as a member of the Consumer Financial Protection Bureau’s Taskforce on Federal Consumer Financial Law. She is also currently on the Governing Committee for the Conference on Consumer Finance Law and was previously Council Chairman for the Town of Chevy Chase View, Maryland. 

Jean is admitted to practice in Maryland and her practice in the District of Columbia is limited to matters and proceedings before federal courts and agencies in accordance with D.C. Ct. App. R. 49(C)(2) and (3). 

Jean received her law degree in 1977 from the University of Texas School of Law. She holds a Bachelor of Arts with Departmental Honors from Oklahoma State University.