Florida is moving toward one of the most expansive contract oversight frameworks in the country—the proposed Elderly and Disabled Adult Contract Protection Act. Florida Senate Bill 120 would require sellers working with covered adults to record a full video review of every contract and store that recording for at least five years. This would apply to creditor and non-creditor sellers and would include F&I products such as vehicle service contracts, GAP waivers and related aftermarket coverage.
Overview of the Florida Elderly and Disabled Adult Contract Protection Act
It establishes new safeguards for adults 65 and older and for individuals with qualifying disabilities who enter into high-value consumer contracts. The bill requires these consumers to review contract terms in a video recording session before signing certain agreements, including large vehicle transactions.
The aim is to reduce instances of deceptive or unfair practices by standardizing how contract terms are communicated and documented for vulnerable consumers. While the bill applies broadly across industries, it has direct implications for auto lending, dealer networks, and F&I product companies whose contracts fall within the statute’s threshold criteria.
Why it Matters to Auto Lenders and F&I Product Companies
The proposed requirements of the Elderly and Disabled Adult Contract Protection Act increase operational complexity at every point of the product lifecycle. For auto lenders and F&I product companies, the bill has several implications:
- Higher evidentiary expectations: In any downstream dispute, the state would expect full audiovisual proof of how contract terms were explained.
- Dealer workflow disruption: Dealers selling GAP waivers, VSCs, or appearance protections would need structured processes and technology to record each explanation.
- Data governance challenges: Retaining and retrieving recordings for up to five years requires consistent systems, storage, and indexing.
- Alignment with servicing obligations: When cancellations, refunds, or benefit disputes arise, lenders may need access to video evidence to validate disclosures.
The Florida Bar highlighted that the bill’s intent is “to ensure covered adults fully understand the financial obligations they are entering.” For lenders, it also creates a higher bar for validating dealer processes and ensuring alignment with product rules and funding requirements.
How to Prepare for the Florida Contract Protection Requirements
Given the direction of state activity and the specific operational requirements proposed in Florida, lenders and F&I product companies should:
- Define dealer disclosure and documentation obligations
- Confirm system readiness for recorded contract reviews
- Ensure product data consistency and audit-ready record retention
Embedding compliance into the full product lifecycle is essential as states continue to tighten expectations.
Other States Signaling Broader Contract Oversight Momentum
Florida SB120 is just one story we are closely tracking. Several states are advancing rulemaking and enforcement activity that reflects a broader shift toward tighter oversight of F&I products, dealer practices, and disclosure standards.
Additional State Developments to Watch
- California Add-On Product Restrictions
- Maryland VSC Standards Update
- Alaska Pre-Approval Requirements for Service Contracts
- New Disclosure Trends Emerging Across Multiple States
Visit our Resource Center for ongoing coverage of state-level developments, operational guidance, and emerging trends in F&I product oversight.
Explore More Regulatory Updates and F&I Product Insights
These highlights represent only a portion of the regulatory activity F&I Sentinel is tracking. Our customer-only newsletters provide the full report, including effective-date timelines, state-by-state analysis, and operational insights from our compliance specialists. Subscribers receive exclusive updates each month to help ensure their organizations remain compliant, efficient, and audit-ready.
If you’d like help assessing how Florida’s new requirements or other state-level changes impact your operations, connect with the F&I Sentinel Concierge Compliance team for a no-obligation discussion.
The information provided in this post does not and is not intended to constitute legal advice; instead, all information, content and materials referenced are for general informational purposes only. Readers should contact their attorney to obtain advice with respect to any particular legal matter.
