The FTC published a full FAQ document on Sept. 15, following the warning letters that went out to 97 dealership groups back in March. This isn't new law, but it's the clearest the agency has ever been about how existing law applies to a car ad.
🎙️ Paul and Kyle break down every line item on today's Automotive State of the Union episode.
Why Is the FTC Doing This Now?
The agency's own framing is worth sitting with: when the price in an ad isn't the price a customer actually pays, the damage doesn't stop at one frustrated buyer. It breaks comparison shopping across the whole market, and it punishes the dealers advertising honestly while rewarding the ones who aren't. That's the enforcement logic behind everything else in this document.
Remember this one?
Bold claim. Can’t say I wouldn’t at least be curious to visit my local dealer.
What Has to Be in the Advertised Number, and What Can Stay Out?
Must Be Included | Can Be Left Out |
|---|---|
Any dealer-required fee, including doc fees and leasing fees | Government-required taxes the consumer pays directly |
The full mandatory fee, even if some customers get a discounted version | State-required doc fee disclosures (can run alongside, don't replace this rule) |
The price any consumer can walk in and pay | MSRP, rebates, conditional discounts (as long as they're less prominent) |
Prominence isn't just about font size, either. The FTC specifically calls out placement and visual weight: a smaller-font real price sitting where a customer's eye lands first still fails the standard.
Does This Apply Everywhere You Advertise?
Yes. Dealership sites, third-party sites, social media, print, road signs, phone calls, texts. One consistent standard across every touchpoint, which means:
A price that's compliant on your website but not on a Facebook post is still a violation
Third-party advertisers and OEMs share responsibility if they control the ad
There's no exemption for informal channels like a text from a salesperson
What About Negotiating, Add-Ons, and In-Transit Inventory?
All still allowed, with guardrails. Customers can negotiate below the advertised price. Dealers can sell optional protection packages and accessories. In-transit or offsite vehicles can be advertised, including with a representative stock photo for new units, as long as the ad makes clear the car isn't physically on the lot and isn't already allocated to someone else's paid order.
Used and antique vehicles don't get the stock-photo option. The FTC's position is that a shopper looking at a used car ad should reasonably expect to see the actual car being sold.
The FTC's bottom line, stated plainly in the document: this has always been the rule. There is no grace period.
Who's Actually Liable If an Ad Gets This Wrong?
Everyone with control over it. Dealers, third-party advertisers, and OEMs can all be held responsible, and the FTC is now accepting public reports of suspected violations, ads and contracts included.
Consider This Today
Pull this FAQ document and walk it line by line with everyone who touches a price before it reaches a customer: sales, marketing, your ad vendors, and anyone on your team who posts about pricing on social media.
