IRVING R. KAUFMAN, Circuit Judge:
As an independent federal administrative agency charged with preventing “unfair methods of competition” and “unfair or deceptive acts or practices,” the Federal Trade Commission (“FTC” or “Commission”) historically has operated in areas of dual state-federal regulation. Consumer warranty law is one example. While the protection of consumers from unfair practices is a traditional state police power function, federal laws and administrative regulations may operate in tandem with— or even preempt — state law under the Supremacy Clause of the United States Constitution, Article VI, Cl. 2.
This appeal raises the general question whether a consent order entered into by the FTC similarly may preempt state law. Unlike an agency regulation which has industry-wide effect, a consent order is binding only on the parties to the agreement. Answering in the affirmative, we also must address whether the instant FTC Consent Order requiring General Motors Corporation (“GM” or “General Motors”) to operate under the auspices of the Better Business Bureau (“BBB”) an informal arbitration program for resolving consumer complaints preempts either the substantive de-cison-making criteria or the procedural and record-keeping requirements of the New York New Car Lemon Law, ch. 799, 1986 N.Y., laws 1882, amending New York General Business Law § 198-a (“Lemon Law” or “Statute”).
BACKGROUND
The dispute arose after New York State amended its business code to require that any existing manufacturer’s informal dispute settlement mechanism conform to the requirements of the State’s new Lemon Law. General Motors brought suit on December 1, 1986, in federal district court seeking a declaration that certain provisions of the state Statute were unconstitutional and an injunction restraining the enforcement of these provisions with respect to GM’s federally mandated consumer arbitration program. The Attorney General moved to dismiss the suit under Fed.R. Civ.P. 12(b)(6) for failure to state a cause of action for which relief may be granted. GM cross-moved for summary judgment.
Denying the State’s motion to dismiss and granting summary judgment, Judge Haight of the Southern District of New York held that the 1983 FTC Consent Order requiring GM to establish a consumer arbitration program preempts the New York Statute on several grounds. The district court found that the FTC order “occupies the field,” to the exclusion of state regulation, within the narrow context of disputes between GM and its consumers. 703 F.Supp. 1103, lili (S.D.N.Y.1989). The district court further held that the Lemon Law conflicts with the arbitral processes mandated by the FTC Order in a manner creating “an obstacle to the accom[37]*37plishment and execution of the full federal purposes and objectives, as expressed in the consent order.” Id.
We reverse the judgment and order of preemption and dismiss GM’s complaint. While an FTC consent order may in some circumstances preempt state law, we do not believe the agreement entered into by GM and the Commission was intended to have this effect on the provisions of the state Lemon Law at issue.
We begin with a summary of the FTC negotiations and state legislation that form the background of this dispute. In 1980, the FTC issued a complaint against GM for failing to notify consumers about serious engine and transmission defects in certain GM cars and light trucks. Avoiding the expense, delay and risks of litigation, the FTC negotiated and entered into a Consent Order requiring GM to implement a nationwide third-party arbitration program, administered by the BBB, to settle complaints of individual owners relating to the defective powertrain components. 102 F.T.C. 1741, 1749. The final Order was preceded by a preliminary proposal which was published and submitted for public comment under agency rules. 48 Fed.Reg. 20730 (1983).
Despite the opposition of numerous consumers and state attorneys general (including defendant-appellant Robert Abrams of New York) to the proposed settlement, the FTC issued the Consent Order on November 16, 1983, providing for case-by-case arbitration rather than direct redress to consumers.1
The program established by the Consent Order marks an “experiment” by the FTC designed to assure that the consumer receives fair and equitable treatment at the hands of the manufacturer. Its principal characteristics are the use of untrained arbitrators chosen from broad segments of the community who “make common sense adjudications based on their own sense of fairness.” The arbitrators might include, for example, “lawyers, professors, accountants, company executives, housewives, trade association personnel.” The third-party arbitration is wholly voluntary for consumers and the results are binding only on GM, 102 F.T.C. at 1761 — i.e., consumer participation in GM’s arbitration program is not a precondition or a bar to pursuing other remedies.
The Order provides for the BBB to administer the General Motors program in accordance with the provisions of the Consent Order, the BBB’s Uniform Rules for Arbitration, the General Motors Zone Handbook for Third Party Arbitration and the General Motors Consumer Arbitration Handbook. Significant to this appeal, these documents, incorporated into the Consent Order, contain two explicit references to state law.
Section 27B of the BBB’s Uniform Rules for Arbitration states:
The arbitrator may make any decision, which the Arbitrator deems fair and equitable within the scope of your agreement to arbitrate, provided state law does not prohibit all or part of that decision.
102 F.T.C. at 1774.
Section 3 provides that “[t]he law of the state where your dispute is arbitrated shall apply.” 102 F.T.C. at 1771.
Effective Sept. 1, 1983, the New York legislature enacted its original Lemon Law, codified as section 198-a of the State General Business Law. The Law created a statutory warranty requiring a manufac[38]*38turer to repair free of charge any new motor vehicle that does not conform to its express warranties for a statutorily specified period of time — two years or eighteen thousand miles, whichever comes sooner. § 198-a(b).
In addition, any defect during this period “substantially impairing] the value of the motor vehicle” that proves unrepairable after a “reasonable number of attempts” renders the vehicle a “lemon,” entitling the consumer to a refund of the full purchase price or replacement. § 198-a(c). The Statute defines “reasonable number of attempts” as four or if the vehicle is out for repair for a cumulative total of 30 or more days. § 198-a(d). These remedies are available to any consumer who first resorts to a manufacturer’s informal dispute mechanism (if one exists) that complies with minimum federal standards. § 198-a(g).
The 1986 amendments to the Lemon Law added that “[i]f a manufacturer has established an informal dispute settlement mechanism, such mechanism shall comply in all respects with the provisions of this section-” § 198-a(g). Subsection (m) sets forth the “minimum” Lemon Law requirements for a manufacturer’s informal dispute settlement mechanism. GM primarily challenges the requirements that arbitrators be “trained in arbitration and familiar with the provisions of [the Lemon Law]” and that they apply Lemon Law remedies. § 198-(m)(l)(i), (iii).
The major differences between the Consent Order and the New Car Lemon Law may be summarized as follows:
1) The Statute requires the consumer to resort to a manufacturer’s dispute resolution mechanism before seeking judicial relief under the Lemon Law, whereas the Consent Order makes participation in the GM-BBB arbitration program wholly optional;
2) The Lemon Law specifies standards for liability and redress for statutorily determined automotive “lemons,” as compared with the “fair and equitable” open standard of GM’s program;
3) Under the Lemon Law, arbitrators must be “trained in arbitration,” “familiar with” the New York Lemon Law, and “provided with a written copy of the provisions of” the Lemon Law, rather than merely untrained community arbitrators called for in the Order;
4) The Statute adds recordkeeping requirements to the reporting provisions contained in the Consent Order.
The New York Statute also directed the Attorney General to create an “alternative arbitration mechanism” to be conducted by professional arbitrators appointed by the Attorney General who must apply Lemon Law standards and remedies.2 This separate arbitration forum has been available to consumers since January 1, 1987.
DISCUSSION
I. Authority to Preempt
We initially must address, as a matter of first impression for this court, whether a consent order entered into by a federal administrative agency can ever preempt state law. We agree with Judge Haight’s conclusion below that consent orders may be afforded preemptive weight in some circumstances.
The Supremacy Clause of the United States Constitution, Article VI, Cl. 2, provides:
“This Constitution, and the Laws of the United States which shall be made in Pursuance thereof ... shall be the Supreme Law of the Land ... the Constitution or Laws of any State to the Contrary notwithstanding.”
While the Framers of the Constitution could not have envisioned the burgeoning of modern administrative procedure, the Supreme Court has interpreted “laws” under the Supremacy Clause to embrace both [39]*39federal statutes and administrative regulations. Fidelity Savings & Loan Ass’n. v. de la Cuesta, 458 U.S. 141, 153, 102 S.Ct. 3014, 3022, 73 L.Ed.2d 664 (1982) (“Federal regulations have no less pre-emptive effect than federal statutes.”). See also, Hillsborough County, Fla. v. Automated Med. Labs, Inc., 471 U.S. 707, 713, 105 S.Ct. 2371, 2375, 85 L.Ed.2d 714 (1985) (“We have held repeatedly that state laws can be pre-empted by federal regulations as well as by federal statutes.”); Capital Cities Cable, Inc. v. Crisp, 467 U.S. 691, 104 S.Ct. 2694, 81 L.Ed.2d 580 (1984) (same, quoting Fidelity).
The Attorney General urges us to hold that a consent order may never be accorded preemptive weight because it lacks the administrative safeguards of a regulation and does not reflect a considered policy choice of the agency. We reject this argument as an exaltation of form over substance.
Congress has authorized the FTC to exercise its supervisory powers under the Federal Trade Commission Act in a variety of ways — raning from industry-wide rule-making to case-by-case adjudication, including issuing consent orders. Federal Trade Commission Act ¶ 5(a)-(g), 15 U.S.C. § 45. See also, Russo v. Texaco, Inc. 630 F.Supp. 682, 684-85 (E.D.N.Y.), aff'd., 808 F.2d 221 (2d Cir.1986). It is well established that when developing law on a subject, an agency usually has a choice between the method of rulemaking and that of adjudication. SEC v. Chenery Corp., 332 U.S. 194, 202, 67 S.Ct. 1575, 1580, 91 L.Ed. 1995 (1947). Although frequently described as quasi-legislative or gwasi-judicial power, see, e.g., Morrison v. Olson, 487 U.S. 654, 108 S.Ct. 2597, 2618-19, 101 L.Ed.2d 569 (1988); C.P. Chemical Co., Inc. v. United States, 810 F.2d 34, 37-38 (2d Cir.1987), both types of agency actions have the binding force of “federal law.” See generally, K.C. Davis, 3 Administrative Law Treatise, § 14.01 (1988).
The Supreme Court has recently stated that “[preemption may result not only from action taken by Congress itself; a federal agency acting within the scope of its congressionally delegated authority may pre-empt state regulation.” Louisiana Public Service Commission v. FCC, 476 U.S. 355, 369, 106 S.Ct. 1890, 1899, 90 L.Ed.2d 369 (1986). Just as when reviewing a federal regulation, we should not disturb an agency’s action intended to preempt state law which embodies a “reasonable accommodation of conflicting policies that were committed to the agency’s care by statute.” Fidelity Savings, 458 U.S. at 153-54, 102 S.Ct. at 3022-23 {quoting United States v. Shimer, 367 U.S. 374, 383, 81 S.Ct. 1554, 1560, 6 L.Ed.2d 908 (1961)). In determining whether a consent order may have preemptive effect, we focus our inquiry on whether the federal agency is acting reasonably and within the scope of its congressionally delegated authority.
The FTC was clearly authorized to enter into the instant Consent Order regulating consumer arbitration between GM and its consumers. The Commission’s decision to agree to a settlement in the face of the expense, delay and risks of litigation appears to have been a reasonable policy choice, particularly in light of the intensive negotiations and extensive public comment that informed its decision. Moreover, the fact that the Consent Order is a product of compromise and negotiation does not preclude it from having the power of preemption; rather, this becomes one factor in determining whether the Commission’s action was intended to have preemptive effect.
Thus, we hold that a consent order reflecting a reasonable policy choice of a federal agency and issued pursuant to a congressional grant of authority may preempt state legislation. The mere fact that the instant Order has been entered, however, is insufficient to preclude supplemental state regulation. As with any preemption analysis, the lodestar of our inquiry is the “intent” of the FTC in entering into the Consent Order.3 California Fed[40]*40eral Savings and Loan Ass’n. v. Guerra, 479 U.S. 272, 107 S.Ct. 683, 93 L.Ed.2d 613 (1987) (citing Shaw v. Delta Airlines, Inc., 463 U.S. 85, 95, 103 S.Ct. 2890, 2898, 77 L.Ed.2d 490 (1983)).
II. Intent to Preempt
The Supreme Court has fashioned clear rules for guiding our search for intent in this area. Absent an indication of express intent to preclude state regulation, preemption would be implied in two ways. The federal scheme of regulation may be so comprehensive in a specific area that it may be reasonable to infer an intent to “occupy the field,” leaving no room for supplemental state regulation. Rice v. Santa Fe Elevator Corp., 331 U.S. 218, 230, 67 S.Ct. 1146, 1152, 91 L.Ed. 1447 (1947). Even where there has not been a complete displacement of state regulation in a particular area, state law is preempted when it actually conflicts with federal law, so that compliance with both federal and state regulations is physically impossible, Florida Lime & Avocado Growers, Inc v. Paul, 373 U.S. 132, 142-43, 83 S.Ct. 1210, 1217-18, 10 L.Ed.2d 248 (1963), or the state law “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress [or the federal agency], Hines v. Davidowitz, 312 U.S. 52, 67, 61 S.Ct. 399, 404, 85 L.Ed. 581 (1941).
There is no explicit statement in the FTC Consent Order of an intention to preclude state regulation. Accordingly, we must examine whether the 1983 Order was intended to “occupy the field” of GM-sponsored consumer arbitration over warranty disputes or whether it would be impossible to comply with both the FTC Order and the Lemon Law or whether compliance with the Lemon Law would frustrate the purposes of the FTC Order. Specifically, we must determine whether there is anything objectionable about the Statute’s requirements that consumers resort to GM’s arbitration program as a precondition to seeking relief in court under the Lemon Law; or that GM’s community arbitrators apply Lemon Law standards and procedures.
A. The Requirement of "First Resort"
No one contests that New York may establish a separate consumer dispute resolution mechanism, replete with substantive and procedural regulations, in addition to GM's federally mandated program. Instead, GM challenges § 198-a(g)'s purported requirement that a consumer seeking relief under the Lemon Law first submit to a manufacturer's existing arbitration program-e.g., the instant GM-BBB program. GM argues that this provision eliminates the voluntary aspect of the GM-BBB program and forecloses consumer choice by "requir [ing] consumers to resort to the FTC-GM consumer arbitration program as a precondition to seeking relief under the New York Statute." GM urges us to immunize its program from state legislation so that it would preserve for the consumer the "choice of opting for a non-binding informal arbitration system based on equitable judgments by lay persons.""4
While recognizing that the state legislation is far from a model of clarity, we believe that GM and the dissenter partially misinterpret these provisions of the Lemon Law. We read section 198-a(g) to require a consumer to submit to a manufacturer’s existing arbitration program before bringing suit under the Lemon Law, but not prior to pursuing relief under the newly created State’s Attorney General arbitration program applying Lemon Law, or prior [41]*41to seeking judicial relief outside the Lemon Law.5 In effect, subdivision (g) creates an exhaustion requirement which makes participation in a manufacturer’s existing dispute resolution mechanism a prerequisite to seeking judicial relief under the Lemon Law. In our view, this statutory scheme neither harms the consumer nor unconstitutionally burdens federal regulation.
The Lemon Law not only permits three separate avenues of relief to remain available to the consumer — the GM-BBB program, New York’s Attorney General arbitration mechanism, and judicial relief — but these routes of redress become meaningful under its terms. In various subtle but significant ways these forums differ as vehicles for affording relief — for example, the consumer may have to pay a filing fee under the State’s mechanism while GM’s is generally free;6 GM’s program is binding only on the manufacturer while the State’s is binding on both.7 Accordingly, we view the Statute’s exhaustion requirement as merely inducing use of the manufacturer’s program, while preserving the consumer’s option to choose between the State’s and GM’s arbitration programs. These features are not contrary to the intent of the Consent Order which assures that consumers will receive fair and equitable decisions when they submit to GM’s arbitration program.
We now address the thrust of GM’s complaint: namely, the requirement that its arbitration program must comply with the substantive decisional criteria and record-keeping procedures of the Lemon Law.
B. Other Requirements
GM claims that it is inconceivable that the FTC intended to permit state regulation of issues covered by the Consent Order in light of its “having negotiated a detailed agreement, having gone through a lengthy comment process, and having resolved debated issues about the decree.” We draw the opposite inference.
When Congress legislates in a field traditionally occupied by the states, “we start with the assumption that the historic police powers of the States were not to be superseded by [federal law and agency action] unless that was the clear and manifest purpose of Congress.” Pacific Gas & Electric Co. v. Energy Resources Comm’n, 461 U.S. 190, 206, 103 S.Ct. 1713, 1723, 75 L.Ed.2d 752 (1983) (quoting Rice v. Sante Fe Elevator Corp., 331 U.S. 218, 230, 67 S.Ct. 1146, 1152, 91 L.Ed. 1447 (1947). Preemption “is not lightly to be presumed.” California Federal Savings, 479 U.S. at 272, 107 S.Ct. at 685. Because consumer protection law is a field traditionally regulated by the states, compelling evidence of an intention to [42]*42preempt is required in this area. See Envtl. Encapsulating Corp. v. City of New York, 855 F.2d 48, 58 (2d Cir.1988); Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. Abrams, 697 F.Supp. 726, 730 (S.D.N.Y.1988).
As the Supreme Court has cautioned:
To infer pre-emption whenever an agency deals with a problem comprehensively is virtually tantamount to saying that whenever a federal agency decides to step into a field, its regulations will be exclusive. Such a rule, of course, would be inconsistent with the federal-state balance embodied in our Supremacy Clause jurisprudence.
Hillsborough County, 471 U.S. at 717, 105 S.Ct. at 2377. This concern is reinforced by the imbalance that a finding of preemption would create among car manufacturers. If we read the Consent Order to preclude all state regulation of the GM-BBB arbitration program, GM would gain an immunity from state law while manufacturers who establish voluntary dispute resolution mechanisms would have to comply with the Lemon Law.8 Although we are mindful that the GM-BBB program was intended to be “experimental,” we are unable to infer that the FTC Order also intended to grant GM such special insulation.
Moreover, the references to state law found in the documents incorporated into the Consent Order indicate that the FTC did not intend the Order to “occupy the field” of consumer warranty law and arbitration between GM and its disgruntled consumers. Conceivably, the boilerplate reference to state law found in Section 3 of the BBB rules may encompass only choice of procedural laws governing arbitration. GM’s claim, however, that Section 27B of the BBB Rules which provides that an arbitrator may make any fair and equitable decision “provided state law does not prohibit all or part of that decision” only refers to substantive law outside the context of the arbitration process seems strained:
This provision means that no decision can require any party to perform an action that would put the party in jeopardy under any other law. For example, if an arbitrator decides a vehicle would achieve better fuel economy if the catalytic converter were removed, he may not “award” the removal of the catalytic converter in contravention of state law. Similarly, an arbitrator could not order seat belts removed as part of a remedy, where cars were required to have them. Again, however, this provision does not and is not intended to substitute state substantive law for the sense of fairness judgment of the arbitrator as to what remedy, if any is appropriate.
Affidavit of Dean W. Determan.9
Determan’s first and last statements are contradicted by the examples on which he relies. While his scenarios may be correct, we fail to discern in Section 27B a distinction between state law which establishes a manufacturer’s obligations with respect to the safety features (personal or environmental) of a car and state law which establishes a manufacturer’s duties with respect to remedying defects. In our view, for example, it should follow logically from these illustrations that an arbitrator should [43]*43not be allowed to award the fair value of a defective transmission on the fifth attempt at repair — an arguably equitable award— where state law requires a full refund or replacement of the “lemon” vehicle after the fourth attempt.
Nor do we find compliance with both the decisional criteria under the Lemon Law and the FTC Consent Order impossible. Under the FTC Order, arbitrators are “free to make common sense adjudications based on their own sense of fairness.” Certainly in some circumstances an untrained arbitrator in the manufacturer’s program which sets no guidelines might arrive at an award other than that prescribed under the Lemon Law. A mere difference in results, however, does not render the two schemes incompatible. In addition, we note that the Lemon Law supplies specific statutory standards and relief only in the limited area of “lemons.” While establishing what constitutes a reasonable number of repair attempts and prescribing the terms of automatic redress (i.e., refund or replacement), the Statute, like the FTC order, otherwise defers to the discretion of the arbitrator in fashioning appropriate relief.
It follows from our analysis that the Lemon Law requirements of training and additional recordkeeping are not preempted. The New York Statute merely requires that arbitrators be “trained in arbitration” and “familiar with” the Law’s provisions. There is no requirement that they be “formal” or “professional” arbitrators in conflict with the Consent Order. The record-keeping requirements of section 198-a(m)(3) are not in conflict with the extensive reporting requirements under the Consent Order.
Ostensibly, the purpose of the FTC Consent Order is to assure consumers fair and equitable treatment when submitting complaints about a vehicle’s performance to GM’s arbitration program. GM does not argue that application of the Lemon Law standards of liability and redress necessarily would be unfair or inequitable. Instead, GM argues that the state legislation is preempted because it disrupts the goal of nationwide uniformity engendered in the Order and violates the specific compromise that was struck in the bargaining process. We reject each of these arguments for similar reasons.
While the Order calls for a “nationwide” program, it does not mention the word “uniform.” Because the goal of consumer protection can be achieved without resort to nationwide uniformity, we decline to equate the two by inferring the latter. Similarly, we do not accept GM’s argument that the Lemon Law is inconsistent with the FTC Consent Order because the Order struck a specific compromise — standardless resolution binding only on GM — in lieu of a broad sweeping program of automatic redress designed to aid consumers. While the compromise that was struck did not include federal uniform standards of fairness and equity, there is no evidence that it precluded further regulation by the states.
Before concluding, we pause to give further consideration to the objections of our colleague. According to Judge Winter, GM’s establishment of an arbitration program “appears to be mandatory.... [which] appears to be the result of sheer happenstance in legislative drafting....” This view is clearly contrary to the record and to the all-inclusive language of section 198-a(g). Indeed, GM chose to enter into a consent order with the FTC, mandating the implementation of a nationwide third-party arbitration program, to avoid unpleasant litigation arising out of the FTC’s 1980 complaint. Neither intentionally nor inadvertently has New York singled out GM for disparate treatment. Any manufacturer that places itself in a similar situation would be subject to the same requirements.
The dissenting opinion also argues that “the issue before us is not the traditional preemption question of whether a federal policy or procedure invalidates a state policy or procedure.... [but] whether New York is unnecessarily interfering with a federal remedial procedure.” We fail to discern anything novel or untraditional in this restatement of the law. Moreover, dual state and federal regulation in a given area may assume various forms; e.g., the state regulation may operate in tandem [44]*44with or independent of the federal law. The instant FTC Consent Order does not indicate any intent to insulate GM’s program from supplementation by state regulation. Since the Lemon Law primarily supplies standards for what is fair and equitable, application of its standards and remedies (which leave wide discretion to the arbitrator) by arbitrators in the GM program does not unnecessarily interfere with the open-ended federal remedial measures.
Finally, we emphasize our belief that the result we reach is principled and fair — not “mischie[vous],” as the dissenter unwisely characterizes it. Companies will not be dissuaded from entering into consent decrees involving BBB arbitration because of our decision. Rather, they will be mindful of the need to bargain for preemption in the specific compromises they reach.
CONCLUSION
For the foregoing reasons we reverse the order of summary judgment and dismiss the complaint below.