Although the Fifth Circuit in effect nullified the CARS Rule, and the FTC may pursue a different rulemaking agenda under the new administration, auto dealers remain subject to existing FTC rules, several of which prohibit conduct that the CARS Rule was intended to target. For example, Section 5 of the FTC Act's prohibition against unfair or deceptive acts or practices ("UDAP") would prohibit a dealer from misrepresenting costs associated with purchasing a vehicle, as well as from engaging in "bait and switch" tactics such as advertising a vehicle for sale at a lower price than what is actually available. STATE ENFORCEMENT ACTION State attorneys general ("AGs") could increase their scrutiny of the auto lending industry and pursue enforcement actions against dealers and/or lenders under their state statutory UDAP authority, particularly those who view the Fifth Circuit CARS Rule decision as a setback in consumer protection.