Many dealers don’t think about potential gaps in their F&I documentation until a problem arises. Maybe it’s a customer complaint you’re able to resolve quickly before it becomes anything more. Or the complaint gains traction online, damages your reputation, and attracts regulatory attention. Either way, today’s compliance environment leaves little room for assumptions.
In recent years, the FTC and state attorneys general across the U.S. have shown that no dealership is too large or too small to attract enforcement attention. Just as notable, regulators are increasingly naming individuals in enforcement actions.
The short version: Proper documentation is essential in today’s compliance landscape. LAW®’s free F&I Document Review can help identify potential gaps before they become problems.
Today’s compliance landscape: Big groups, small dealerships, and the people who run them
Federal and state regulators have pursued dealerships of all sizes and, in many cases, the individuals involved in day-to-day operations.
Large, multi-rooftop groups. In April 2026, the FTC and Maryland Attorney General reached a settlement with Lindsay Automotive Group requiring the company to refund more than $75 million to consumers and pay a $3.1 million civil penalty. The complaint alleged the dealerships advertised deceptively low prices before adding mandatory fees and unwanted add-ons. In addition to the corporate entities, three dealership officers, including one who was no longer employed by the group, were named as defendants.
In a separate pending case, the FTC alleges that Asbury Automotive Group and three of its Texas dealerships charged consumers for add-on products they never agreed to purchase through a practice known as "payment packing." The complaint also names the general manager of the three Texas stores individually, with the FTC arguing they could be held personally liable given their direct control over financing and sales policy.
Mid-size groups. In December 2024, the FTC and Illinois Attorney General secured a $20 million settlement with Leader Automotive Group over allegations involving deceptive pricing and unconsented add-on charges. The settlement highlights that large penalties aren’t limited to multi-state dealer groups.
Single dealerships. In August 2026, the FTC and the State of Connecticut secured a $4 million settlement with a single Manchester, Connecticut dealership and its owners and managers over allegations involving deceptive certified-vehicle pricing. This settlement shows size doesn’t provide protection from regulators.
And it's not slowing down. In March 2026, the FTC sent warning letters to 97 auto dealer groups of various sizes regarding deceptive advertising and pricing practices. Notably, the letters resulted from the FTC's own review of dealer advertising and pricing, not individual consumer complaints.
While every case is different, many share a common theme: regulators closely examine dealership documentation to evaluate disclosures, pricing practices, and customer consent.
How quality F&I documents can help
Many enforcement actions involve allegations of wrongdoing, but outdated or poorly designed documents can create risk even when a dealership is acting in good faith.
Documents that don’t clearly explain charges, capture customer consent, or are unnecessarily vague can create vulnerabilities regulators may scrutinize during an investigation.
Close gaps now, before there’s an issue. No dealer can predict whether they will receive a warning letter or become the subject of an investigation. What you can do is use documents designed to withstand the scrutiny of today’s regulatory landscape.
LAW F&I Document Review
When was the last time you reviewed your F&I documents? Was that review conducted by someone with experience in automotive finance law? If you are unsure about either answer, consider requesting a free LAW F&I Document Review.
The review begins with an experienced Compliance Consultant evaluating your current F&I documents for potential compliance gaps, including these common issues:
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Outdated documents
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Areas of risk not addressed
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Conflicting text
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Lack of standardization and consistency
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Lack of strategic redundancy in documentation
After review, your consultant will share their findings and recommendations, including opportunities to help reduce compliance risk through the use of up-to-date, state-specific documents maintained by a team of in-house and outside legal professionals.
The bottom line
When it comes to automotive consumer finance and F&I documentation, being proactive instead of reactive is essential.
Recent enforcement actions have touched dealerships of every size, along with the individuals who work within them. That’s not a reason to panic, but it is a reason to evaluate your F&I documents, identify potential gaps, and take steps to improve or replace documents that aren’t up to the task of helping to protect you and your business.
Disclaimer: The enforcement actions referenced are based on publicly available complaints, settlements, and regulatory announcements. Settlements do not constitute an admission of guilt or liability, and allegations are not proof of wrongdoing.