Last reviewed: 15 September 2026

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Three recent GAP and add-on enforcement actions, in the regulators' own words

This page is different from the rest of this Library: instead of explaining a law, it reports three real, closed, publicly documented government enforcement actions touching GAP waivers and other dealer add-on charges. Each summary below states only what the government's own filing or press release says — a consent order's findings, a settlement's terms — not this site's own judgment of any company. Nothing here is a grade, a pass/fail verdict, or part of our Register, which is reserved for our own standard-by-standard assessment of a provider; this is a report of the public record, the way our CARS Rule page already reports the FTC's own rulemaking history.

CFPB consent order: Toyota Motor Credit Corporation (November 20, 2023)

On November 20, 2023, the Consumer Financial Protection Bureau issued a consent order (2023-CFPB-0015) against Toyota Motor Credit Corporation (TMCC), the U.S. financing arm of Toyota Motor Corporation. The order addresses TMCC's handling of optional add-on products sold alongside vehicle loans and leases — including Guaranteed Asset Protection (GAP) agreements, Credit Life and Accidental Health coverage, and vehicle service contracts — together with separate findings about TMCC's credit-reporting practices. The order requires TMCC to pay $60 million in total: $48 million in redress to affected consumers and a $12 million civil penalty.

According to the order, the Bureau found that TMCC failed to ensure consumers received refunds of the unearned portion of prepaid GAP and CLAH charges when a loan was paid off or a lease ended before its term, and that flawed refund calculations caused some consumers to receive incorrect amounts. The order also finds that, between 2016 and 2021, TMCC routed more than 118,000 consumer calls requesting cancellation of these add-on products through a "retention hotline" whose representatives were directed to discourage cancellation — including, per the order's findings, telling a consumer that cancellation required a written request only after that consumer had verbally asked to cancel three times. The order requires TMCC to stop tying employee compensation or performance measures to consumers' retention of these add-on products, to make cancellation genuinely easy including online, and to monitor its dealer network for add-on products imposed on consumers without consent.

Colorado Attorney General's GAP Refund Initiative (2022–2023)

Beginning in 2021, the Colorado Attorney General's office opened an inquiry into whether GAP administrators and lenders doing business in Colorado were paying the full GAP benefit that state law requires. On January 4, 2023, the office announced assurance-of-discontinuance settlements with two Colorado-based credit unions, Bellco Credit Union and Canvas Credit Union, resolving findings that the credit unions had not paid the full GAP benefit owed to some borrowers. The two credit unions refunded a combined total of more than $4 million to 49,487 Colorado borrowers, and each separately paid a $100,000 penalty and agreed to change its practices going forward.

On May 8, 2023, the office announced separate assurance-of-discontinuance settlements with four GAP administrators doing business in Colorado — Safe-Guard Products International, Inc.; Jim Moran & Associates, Inc.; Norman & Co., Inc.; and National Auto Care Corporation — securing more than $2.87 million in restitution for 3,550 Colorado consumers. Individual settlement amounts ranged from $4,036.56 to $1,655,124.78. Safe-Guard Products International separately paid the Attorney General's office $100,000 for costs and future consumer-protection purposes.

FTC and Maryland Attorney General settlement: Lindsay Automotive Group (announced April 2, 2026)

On December 27, 2024, the Federal Trade Commission and the Office of the Maryland Attorney General filed a joint complaint in the U.S. District Court for the Eastern District of Virginia (Federal Trade Commission et al. v. Lindsay Chevrolet, L.L.C. et al., No. 1:24-cv-02362) against four related dealership entities operating together as the Lindsay Automotive Group — Lindsay Chevrolet, LLC; Lindsay Ford, LLC; Lindsay Motors, LLC; and Lindsay Management Company, LLC — along with three named individuals: owner and president Michael Lindsay, chief operating officer John Smallwood, and the dealerships' former general manager, Paul Smyth. The complaint alleged that the dealerships advertised vehicles at a specific price but then told some consumers they could only obtain that price by financing through the dealership, and separately charged consumers for add-on products — including GAP waivers and vehicle service contracts — that the complaint alleges some consumers either did not authorize or were told were mandatory.

On April 2, 2026, the FTC and the Maryland Attorney General announced a settlement resolving the complaint. Under its terms, consumers who paid charges in connection with a Lindsay Automotive Group vehicle purchase or lease between April 1, 2020 and December 31, 2025 — more than $75 million in charges in total — are eligible to seek a refund, and Lindsay agreed to pay a $3.1 million civil penalty to the Maryland Attorney General's office. The settlement also requires changes to the dealerships' advertising and add-on sales practices going forward.