The Federal Trade Commission (FTC) recently sent a clear message to the automotive industry: the price you advertise must be the price consumers actually pay (aside from required government charges, like taxes). The agency issued warning letters to 97 automotive groups nationwide, signaling that deceptive pricing practices remain a top enforcement priority.
What the FTC Is looking for
The letters were direct. The FTC identified a list of pricing practices it considers violations of the FTC Act and warned each recipient that they:
“… may be advertising prices for cars that are lower than what you actually charge customers. Such deceptive tactics harm not only consumers, but competition, by making it harder for law-abiding businesses to compete on an even playing field.”
These practices include:
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Advertising a price that doesn't account for all required fees
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Including discounts or rebates that aren't available to every consumer
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Omitting additional required down payment amounts from advertised prices
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Conditioning the advertised price on the consumer using dealer financing
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Requiring consumers to purchase additional items not reflected in the advertised price
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Advertising vehicles that don't exist or aren't available
The common thread? Consumers being drawn in with one number and then hit with a higher one at the dealership. These letters make it clear the FTC is paying attention.
Enforcement isn’t slowing down
Although the FTC CARS Rule was vacated last year, these letters remind the industry that the FTC remains active in the courts. Recent enforcement actions against individual dealerships and large automotive groups were cited directly, a pointed signal that warning letters can precede real legal consequences.
What this means for dealers
Dealers should see this as a compliance moment worth taking seriously. The FTC's strongly-worded request is clear: review the way you advertise prices and confirm they match what consumers will actually pay. The FTC believes all required fees, except required government charges, should be included in the price advertised to consumers.
Beyond advertising, the current compliance landscape underscores the importance of having documentation that supports transparency from start to finish. A sale that begins with an accurate advertised price still needs to close with paperwork that clearly and consistently reflects the full scope of the deal.
Where LAW® can help
LAW F&I documents are crafted with care to meet the federal and state-specific needs of dealers across the U.S. When regulators are scrutinizing the gap between what's promised and what's signed, having a solid foundation built on quality documents isn't just a best practice - it's good business.