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On March 13, 2026, the FTC announced that it sent warning letters to 97 auto dealership groups stating that advertised vehicle prices must reflect the total price consumers will be required to pay, excluding only required government charges such as taxes. The letters emphasize that not doing so could be considered a deceptive pricing practice in violation of Section 5 of the FTC Act.
The warning letters state that the agency is concerned some dealerships may be advertising prices lower than what consumers actually pay at the end of the transaction. The FTC urged recipients to review their advertising and pricing practices, including by comparing advertised prices against actual consumer charges, and stated that it will continue monitoring the market and take additional action as warranted.
The letter identifies several pricing practices the FTC views as unlawful, including:
- Advertising prices that exclude mandatory fees. The FTC stated that advertised prices should include all required fees and charges, other than required government charges, so that consumers can accurately compare offers.
- Using discounts or rebates not available to all consumers. The letter warned against advertising prices based on incentives that not every buyer can actually obtain.
- Omitting required down payment information. The FTC stated that a dealership should not advertise a price that fails to account for an additional required down payment.
- Conditioning the advertised price on dealer financing. The agency warned that advertised pricing should not depend on a consumer using financing offered by the dealer unless that condition is clearly and lawfully reflected.
- Requiring add-on products not included in the advertised price. The letter cited mandatory add-ons and similar charges as another example of potentially deceptive pricing.
Advertising unavailable or nonexistent vehicles. The FTC also warned against using vehicle listings that do not reflect actual inventory.
Putting It Into Practice: The FTC’s letter fits within its broader focus on pricing transparency and allegedly deceptive fee practices across consumer markets (previously discussed here and here). Auto dealers and lead generators should review advertised pricing practices and fee disclosures in light of the FTC’s position.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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