The Fifth Circuit Court of Appeals decided to vacate the Combating Auto Retail Scams (CARS) Rule, also referred to as the Vehicle Shopping Rule, on January 27. In a 2-1 decision, the court vacated the Rule because the FTC did not issue an Advanced Notice of Proposed Rulemaking (ANPRM) before issuing the Final Rule. The court did not address challenges to the Rule’s requirements, but focused only on the FTC’s failure to follow its own rulemaking process. This NADA/TADA victory means that, for now, the FTC cannot enforce the Vehicle Shopping Rule.