FTC Puts Auto Pricing Guidance Into Action In Settlement With Florida Dealership Group

Just three weeks after the FTC released its FAQs on auto pricing, the Commission announced a new enforcement action settling allegations related to many of the very practices that guidance addresses. 

Specifically, last week, the FTC filed a complaint and stipulated order in the Middle District of Florida against Greenway Auto Group, a Florida dealership group with more than 35 locations. According to the complaint, Greenway charged consumers more than its advertised prices, built conditional rebates into those advertised prices, inflated government charges and fees, and sent mailers falsely promising cash prizes to bring consumers into its dealerships. The FTC also alleged that Greenway continued those practices after receiving one of the agency’s March 2026 warning letters. 

The Complaint

The FTC’s central allegation is that Greenway advertised vehicles at specific prices and then charged consumers more by adding fees and claiming advertised prices reflect conditional rebates and discounts only available to a subset of consumers. For vehicles advertised between March 2023 and May 2026, the FTC alleges that more than 92% of consumers paid above the advertised price – by an average of at least $3,354, even after excluding government charges and optional add-ons.

The complaint attributes that gap to several practices. For example, “dealer,” “administrative,” and “document” fees were allegedly charged to over 99% of Kia customers but left out of advertised prices. A $995 “loyalty” fee was allegedly imposed on anyone who was not a repeat customer. The complaint also alleges that Greenway charged $2,295 for a mandatory add-on package on new vehicles that was not included in the advertised price, even though the dealership’s website described the package as “required.” Finally, Greenway allegedly inflated the amount consumers were charged for mandatory government fees, such as license, title, and registration.

The complaint also alleges that Greenway added “ALL-IN PRICE” and “ZERO HIDDEN FEES” claims to its websites after receiving the FTC’s warning letter while continuing to charge more than advertised. Despite telling consumers that “[t]he price you see advertised online is the real price,” a Greenway sales associate later conceded that the “[c]ash price is a little higher” on a vehicle advertised at $37,752 and quoted at $39,854.40. The FTC characterized those website changes as “active steps to conceal” the conduct from law enforcement.

The Stipulated Order 

Notably, the stipulated order includes no monetary relief – a contrast to the multimillion-dollar dealer settlements earlier this year that we discussed in our FAQ post. But the order’s conduct provisions closely track the guidance in the FTC’s FAQs. Whenever Greenway advertises an amount a consumer may pay, it must clearly and conspicuously disclose the “Total Price” as the most prominently displayed price. “Total Price” includes all mandatory fees and charges; only government-required charges may be excluded. Read together with the FAQs, the Greenway order offers dealers a few practical lessons:

• Mandatory charges must be accounted for in the most prominently displayed price. A package that is pre-installed, cannot be removed, and must be paid for is not optional, no matter how a disclaimer describes it.
• Conditional discounts should not drive the headline price. If the advertised price reflects discounts tied to loyalty, financing, or other eligibility criteria, it is not a price every consumer can get, and it should not be the most prominent price.
• Transparency claims must be true. As the complaint illustrates, adding “all-in” or “no hidden fees” language without changing sales practices does not reduce risk – it can increase it.