After the FTC’s second round of conversations with dealers, the direction is getting clearer. But for many retailers, the details are still taking shape in real time.
Phil Gill of Tom Gill Auto Group put it plainly after tuning in.
“I would say they gave strong direction on making sure doc fees were in pricing and that federal law is going to trump state law here,” Gill said.
That aligns with the core message from the FTC’s April 17 webinar with NADA: the most prominent advertised price should reflect the full price a customer can actually pay, outside of required government fees.
As one FTC official put it, “If you’re going to display a price for a car, aside from government fees, you need to be sure a consumer can walk into the dealership and write a check for that price.”
That “total price” standard is the center of everything. It includes dealer-imposed fees like doc fees, must be the most prominent number in the ad, and must be available to every customer.
Don Hall, President and CEO of the Virginia Automobile Dealers Association, reinforced that takeaway in a LinkedIn post, calling out total price, prominence, and universal availability as the FTC’s baseline.
Where things get complicated
For Gill, one of the biggest challenges is how these expectations collide with current workflows, especially around inventory.
“The in-transit vehicle clarification actually adds complexity to our workflow and what our manufacturer has been doing with placing in-transits on our website further out than a couple days,” he said.
There is also the question of shared responsibility. The FTC made clear that accountability follows control, but Gill sees that as a positive shift.
“It helps to know that our third-party partners have a responsibility to this as well. This helps to make sure all parts of the advertising chain are connected and working in the same direction.”
Still, not everything is settled.
“For me, it still seems very unclear if the advertised price translates to payment advertising,” Gill said. “All payments are based on a price and certain rebates, but it didn’t seem clear if these same rules carry over.”
What it means for dealers
Gill’s view is that many dealers are already close, with some important gaps.
“I think that most dealers appear to be following most of the rules, outside of doc fee inclusion, on manufacturer-controlled sites,” he said. “Once the pricing goes to third parties things can get a little murky.”
But the bigger risk is not just the ad. It is what happens after.
“I have seen many examples where the price online states it is available to everybody, but the deal sheet the customer gets has a different price entirely. This is where I see the most exposure.”
That lines up with what others in the industry are saying. The focus is shifting from what is published to whether store teams are trained to stand behind those prices when customers call or walk in.
There is also a market-by-market impact.
“Doc fee pricing will have an impact in certain states and none in others,” Gill said. “In states like Florida, where doc fees lack much regulation, that could introduce new forms of competition between dealers.”
And if payment advertising falls under the same standard, the shift could be even bigger.
“If payment ads have to adhere to the payment being based on a true advertised price, then it will change the whole game,” he said. “Although this isn’t clear right now.”
The throughline
Yes, there is nuance. Lease vs purchase. On-the-lot vs in-transit. Rebates, incentives, and payment structures.
But the center of this conversation is not complicated.
As one dealer marketer put it:
“The most important thing is that the practices we’re using aren’t deceptive. The price we advertise is the price any person can get.”
That is the bar.
And for now, there are still open questions.
“The only thing I would add is that I encourage NADA to provide more guidance on how dealers can get questions to them so they can continue to get answers from the FTC,” Gill said. “There still seem to be a lot of unanswered questions.”
For dealers, this is about alignment. Across OEM feeds, third-party listings, store processes, and team training.
Because the gap between what is shown and what is sold is where the real risk lives. And closing that gap is where the real opportunity is.
