March 19, 2026
With the FTC's March 13 announcement that advertised vehicle prices must reflect the total price — a major change that will impact Virginia dealers — VADA has developed resources you can use starting today to ensure compliance and avoid costly penalties that could impact your bottom line and reputation.
To comply with the FTC Act, the advertised price of a vehicle should be the total price the consumer is expected to pay, which must include all fees and charges (i.e., processing fee and freight) and only excludes governmental fees (i.e, tags, title and taxes).
What it looks like if the FTC investigates your dealership.
Some dealers have reacted to last week’s announcement by the Federal Trade Commission by asking, "We thought the CARS Rule was dead. What's the deal?"
As a reminder, the CARS Rule was vacated last year, but the recent FTC enforcement position has emphasized that the agency intends to enforce against the practices the CARS Rule targeted, by taking the position that dealers must advertise the total "offering price" of the vehicle.
Even without the specific CARS Rule, it is critical that dealers heed this warning shot from the FTC, and they will bring enforcement actions against dealers for deceptive advertising. You do not want to be on the next list of dealers who receive letters from the FTC.
In case you don’t think this is a big deal, consider what an investigation will do to your store, your operations, and your reputation if you don't comply. Here's a preview.
You'll get a Civil Investigation Demand (CID). Dealers investigated by the FTC are usually subject to a civil investigative demand (“CID”). It functions like a subpoena to gain information and documents about the dealership’s operations and transactions with customers. Such CIDs are broad, usually cover several years, multiple rooftops, and are almost impossible to oppose or limit with motions or other legal filings.
You'll need to pay for months of skilled, expensive attorneys and consultants. CIDs are complicated and require the assistance of experienced attorneys and outside third parties to organize production of information and documents electronically. This process is usually one that can take six to 12 (sometimes longer) to complete with rolling productions to the FTC, depending on how broad the CID is and how many stores are involved.
You'll be distracted from business operations. During the FTC’s investigation, the FTC can and often does follow-up with dealers for additional information and may even expand the CID to cover more dealerships and possible additional issues or topic areas. This lengthy and involved process can be disruptive to business operations and eats up vital resources of a dealer group, including the time and efforts of experienced management who are required to organize and collect responsive information and documents while juggling daily dealership operations, as well as the costs associated with employing capable attorneys and third-party vendors to assist with responding to the FTC CID and negotiating any settlement with the FTC.
Your non-compliance will be made public and likely in the news. Any complaint filed by the FTC, and ultimate settlement, is public. Settlements with the FTC are not just limited to monetary penalties – often in the millions of dollars — but also include compliance monitoring, record-keeping, and reporting to the FTC for numerous years, which could even be more problematic for dealers. Additionally, nothing about a settlement with the FTC precludes consumer litigation so a dealer may still be open to further risk and exposure.
You'll pay heavily. Noncompliance is a costly mistake, and fines for the violations could cost thousands of dollars. The FTC letters say the pricing issues violate Section 5 of its code, which carries a fine of $53,088 per violation. It's not immediately clear whether the specific issues listed in the letters would trigger that amount.
Your legal issues may expand. A public complaint and settlement with the FTC is a roadmap for plaintiffs’ attorneys, which can lead to lawsuits from consumers.
Translation: compliance with the CID is extremely costly and time consuming. Take the necessary steps now to protect yourself and your dealership. Visit our FTC Enforcement Resources page for our guidance.