FTC Total Pricing Enforcement Resources - Virginia Automobile Dealers Association

On March 13, 2026, 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." 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). VADA, working with our legal team, has developed a number of resources for dealers to ensure compliance to the FTC.

Sample Compliant Advertisement

FTC Act Advertising Checklist

FTC Enforcement: What an investigation looks like

March 19, 2026

In case you don’t think FTC compliance is a big deal, consider what an investigation will do to your store, your operations, and your reputation if you ignore their warning.

FTC Enforcement: Review Your Social Media Policy

March 18, 2026

Social media postings can be a major hole in your compliance program — and your dealership is responsible for individual employees’ posts. Review our social media guidance.

FTC Enforcement: Add-On Pitfalls

March 17, 2026

Avoid these add-on pitfalls to comply with the Federal Trade Commission’s enforcement of advertising and pricing rules.

FTC Enforcement: Practical Actions Dealers Can Take

March 17, 2026

In the wake of the Federal Trade Commission’s crackdown on advertising and sales practices, VADA offers dealers practical steps your stores can take to comply.

FTC fires warning shot throughout retail automotive industry

March 16, 2026

FTC regulators are making clear that vehicle advertisements must show the true offering price — including all mandatory dealer fees — and dealers should move quickly to review their advertising and sales practices to avoid costly violations.

Questions VADA has received from dealers, along with answers.

If you have questions on the FTC enforcement action, email VADA general counsel Anne Gambardella.

We thought the CARS Rule was dead. What's the deal with this FTC action?

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.

What information should be contained on the vehicle's addendum sticker?

My manufacturer does not allow dealers to advertise a price higher than MSRP. What should I do to comply with the FTC’s position on advertising price?

Dealers should advertise the total selling price, including all mandatory fees, that consumers will be required to pay — even if it violates manufacturer rules. If a manufacturer attempts to withhold ad money, then the issue can be taken to the DMV Commissioner.

There will be many issues to work through with manufacturers. This is one of them.

Dealers should be permitted by the manufacturer to advertise a price that is MSRP + processing fee. A manufacturer should not be able to prevent that. A manufacturer should be able to prevent a dealer from advertising a “market adjustment” or other similar addition to MSRP.

My manufacturer offers incentives that require the customer to finance with the manufacturer's captive finance company. Can I reduce the price of the vehicle by those types of incentives?

No. Under our reading of the FTC position, any conditional incentives should not be used to reduce an advertised price. This incentive is conditional on captive financing, and therefore not available to cash buyers or those who arranged their own financing. Conditional incentives can be advertised as additional possible reductions (i.e., “Additional Offers that You May Qualify For”), but the amount should not be used to reduce the price advertised.

My manufacturer offers incentives that allow the customer to select customer cash or special financing. I understand that customer cash is not available to customers who choose special financing and therefore should not be used to reduce the advertised price. However, my manufacturer reduces my advertised prices by the customer cash amount when it pushes prices to my website.