The Federal Trade Commission released these staff FAQs to clarify how the FTC Act's prohibition on deceptive or unfair practices applies to vehicle price advertising. The guidance is not legally binding, but it signals current enforcement priorities. The core rule running through every answer: the price a dealer advertises must be the actual, walk-in price any consumer can pay — with the only carve-out being government-mandated charges paid directly by the consumer.
- Transparent, truthful pricing is a top FTC enforcement priority.
- Consumers often see one price in ads but pay more after investing time and traveling to the dealership.
- Misleading prices prevent comparison-shopping and undermine informed consumer decisions.
- Dealers that advertise honest all-in prices are unfairly undercut by competitors posting artificially low prices no one can actually get.
- Section 5 of the FTC Act — the ban on deceptive/unfair practices — is the legal basis.
Dealers advertising true all-in prices are protected by this enforcement push, not burdened by it — it targets competitors who lowball ads to generate traffic.
- The advertised price must reflect what a consumer actually pays upon visiting the dealership.
- Any fee required for the consumer to purchase the car must be baked into the advertised price.
- The only exclusion allowed: charges a Federal, State, or local government requires the consumer to pay directly.
- Dealer-required fees that a government merely authorizes (but does not mandate) must still be included.
- Government-required charges the dealer pays but passes on to the consumer must also be included.
Doc fees, dealer-added products marked as mandatory, and any other required charge belong in the headline price — only true government taxes/titling fees paid directly by the buyer can sit outside it.
- All channels are covered: dealership websites, third-party listing sites, social media, print ads, roadside signs, and phone/text communications with staff.
- Any format where a price is presented is subject to the FTC Act's truthfulness requirement.
Train BDC/phone-up staff and social media managers the same way you train F&I — a verbal quote or a text message price carries the same legal weight as a printed ad.
- Yes — on any webpage displaying an amount a consumer may pay, the actual (all-in) price must be the most prominent figure shown.
- This applies to inventory search and results pages as well as individual vehicle listing pages (VDPs).
Audit your website's search-results grid, not just the VDP — the FTC expects the true price to be prominent at every step of the online shopping funnel.
- Yes, as long as the actual price remains the most prominent amount and consumers understand what they must pay to get the car.
- Prominence isn't just about font size — placement and surrounding wording matter too.
- A smaller-font actual price paired with a larger, attention-grabbing MSRP can violate the rule even if font sizes technically differ.
- Conditional discounts (e.g., $1,000 off for first responders) are allowed only if conditions are clearly stated and the walk-in price remains most prominent.
Review ad templates and landing pages for visual hierarchy, not just font size — color, placement, and callout boxes can make a secondary number read as "the price."
- The advertised price must include the full mandatory document fee — e.g., a $40,000 car with an $85 doc fee must be advertised at $40,085.
- No additional charges may be layered on beyond government-required amounts.
- If the dealer discounts the doc fee for some buyers, the advertised price must still reflect the highest fee any consumer could be required to pay.
If your store ever waives or reduces the doc fee for specific deals, the advertised price must still be built on the highest fee a walk-in customer could be charged.
- States vary: some use general deceptive-practices laws, some require separate disclosures, some cap the fee amount, and some mandate specific wording.
- Regardless of state approach, the FTC requires the actual all-in price to be the most prominent amount in the ad.
- State-specific disclosure rules are additive — dealers satisfy the FTC Act first, then layer on any state-required disclosures.
Treat FTC compliance as the floor, not the ceiling — your state's doc-fee disclosure rules still apply on top of the federal all-in pricing requirement.
- Any upfront processing fee due in a lease must be included in ads referencing the total amount due at signing.
- This FTC Act requirement layers on top of — not instead of — the Consumer Leasing Act, Regulation M, the Truth in Lending Act, and Regulation Z.
Lease ads need the same all-in scrutiny as retail ads; coordinate with your compliance resource to confirm Reg M and Reg Z disclosures are still separately satisfied.
- Consumers may negotiate a lower price, but the advertiser's obligation doesn't change: the advertised price must be what any consumer could walk in and pay.
- A price cannot be based on a discount given to only a handful of past buyers — advertising $24,999 when most buyers are actually quoted $26,499 is deceptive.
- Optional protection packages and add-ons are permitted, but dealers may not: imply a required add-on is optional (or vice-versa), claim an installed option can't be removed, misstate its cost, or bill for options the consumer never agreed to.
- The FTC has already brought enforcement actions on add-on misrepresentation and signals it will continue to do so.
This directly touches the F&I box: menu presentations must clearly separate mandatory from optional products, and "already installed" accessories must be presented as removable/declinable if they aren't truly mandatory.
- Vehicles en route from the manufacturer, stored offsite, or available via inventory-sharing may be advertised.
- If a vehicle is not physically on the lot, the ad must clearly disclose that fact.
- A vehicle in transit must genuinely be in transit, must not already be allocated to another paid customer, and must be available for purchase once it arrives.
- Recently sold or otherwise unavailable vehicles generally should not be advertised, and never as a bait tactic to lure shoppers in and upsell them to pricier units.
Sync your website inventory feed with actual lot/in-transit status — stale listings for sold units are a classic bait-and-switch complaint trigger.
- Representative photos are allowed if they truly match the vehicle's make, model, condition, and other material characteristics, and a reasonable consumer would understand it's illustrative.
- Stock photos are more defensible for new vehicles (largely identical units) and vehicles still in transit.
- Used and antique vehicles are rarely identical to one another — consumers reasonably expect the actual unit's photo for those listings.
Flag any used-vehicle listing using a generic stock photo instead of the actual unit's photo — that's a higher-risk practice under this guidance.
- Everyone who controls the advertisement shares responsibility for ensuring the actual price is the most prominent figure.
- Dealers must supply accurate pricing to third parties, take reasonable steps to ensure it's displayed prominently, and avoid internal instructions that contradict that goal.
- Third-party advertisers (listing sites, marketing vendors) must ensure the accurate price is the most prominent amount wherever any figure is shown.
- OEMs must ensure their advertising policies and co-op requirements don't conflict with these pricing rules.
If you rely on a listing syndicator, DMS pricing feed, or OEM co-op template, confirm none of them override your all-in price with a smaller-font or less prominent figure.
- There's no grace period — price transparency is not a new requirement. Section 5 of the FTC Act has applied for decades.
- Any dealer misleading consumers about price is already exposed to FTC action, and the FTC says it will keep monitoring the marketplace.
Treat any pricing-ad audit as urgent, not "nice to have for next quarter" — the FTC considers this guidance a restatement of existing law, not advance notice of a future rule.
- The FTC encourages reporting suspected violations at ReportFraud.ftc.gov, including dealership name and details of the alleged violation.
- Reporters should attach available documentation — copies of ads, actual contracts — in the comments field.
- The FTC states it closely reviews these reports, which can meaningfully inform its consumer-protection work.
Compliant dealers now have a documented channel to report competitors advertising unattainable low prices — useful leverage in a market with uneven compliance.