On June 24, 2009, the President signed the 2009 Supplemental Appropriations Act for Iraq, Afghanistan, Pakistan and Pandemic Flu1 which contained the Consumer Assistance to Recycle and Save Act of 2009,2 popularly referred to as the “cash for clunkers” legislation. The Act established, in the National Highway Traffic Safety Administration, a voluntary program to be known as the “Consumer Assistance to Recycle and Save Program” to provide electronic vouchers to offset part of the purchase price or lease price of a new fuel-efficient vehicle upon the surrender of an eligible trade-in vehicle to a dealer participating in the program.3 The vouchers may be used to offset the purchase price or lease price by $3,500 or $4,500.4