March 17, 2026
Background
On March 13, the Federal Trade Commission announced that it sent 97 dealerships warning letters about advertising and sales practices. In its letter, the FTC states that advertisements are deceptive and in violation of the FTC Act if the price of a vehicle is not the “offering price” from the CARS Rule. To comply with the FTC Act, the advertised price of a vehicle should be the total price the consumer is expected to pay, which shall include all fees and charges (i.e., processing fee and freight) and only excludes governmental fees (i.e, tags, title and taxes).
Today, we look at practical actions dealers can take to comply with the FTC.
For new cars on your lot
Dealers must have addendum stickers to display the vehicle’s price with the processing fee/charge, and they need to be accurate, display the total price of the vehicle, and match the advertised price. Otherwise, the FTC’s view is that the MSRP is your price — and you are unable to charge the processing fee.
On your buyer's order
Buyer’s orders have a preprinted line for the processing fee, which is required to be listed separately. As such, the line for “Price of Vehicle (including Freight, Handling & Delivery)” should not include a price that is the same as the advertised price, but it should be less than the advertised price because the processing fees/charge (which was included in the advertised price) will be separately stated on the order on the “*Processing Fee (for consumer services)” line. Stated clearly: Price of vehicle on buyer's order + Your processing fee = Advertised price. Staff should be properly trained on this.
When talking price to customers
Dealers need to train new and used salespeople on sales practices, specifically what is included in the price of vehicles and how to convey that price accurately to consumers. For example, when a consumer calls the dealership and asks what the out the door price will be, the salesperson must provide the total price, which needs to include the processing fee/charge and freight (if your dealership formerly removed it from the advertised price).