FTC Pricing Transparency: What Independent Dealers Need to Know Right Now

Independent Dealers have always had to deal with changing rules. But what the FTC is doing right now in auto retail is different. When 97 warning letters went out earlier this year, the FTC was not giving dealers a heads-up. It had already reviewed each dealership's ads before sending them.

I have spent my career running dealerships. What I have seen over the past few months is that dealers fall into two groups: those who got the news and immediately checked their ads, and those who figured it would not apply to them.

If you are in the second group, keep reading.

What the FTC Is Enforcing
The rule is simple. The price you advertise must be one that any customer can walk in and pay by check. Not most customers. Not approved buyers. Any customer who sees your ad.

The only things you can leave out of that price are government fees and taxes. Everything else must be included, including your doc fee.

The 97 letters were not sent due to gray areas or fine print. Every one of them had the same problem: the advertised price was not what most customers could actually pay. The FTC reviewed each Dealer's ads before sending them.

The Doc Fee Question Is Closed
Many Dealers still have questions about doc fees. Here is the answer.

Federal law controls, regardless of what your state allows. No state requires Dealers to charge a doc fee. States only permit it. Because the doc fee is optional under state law, it cannot be omitted from your advertised price under federal law.

The FTC is not telling you how much to charge for a doc fee. It only says that whatever you charge must be included in the price you advertise. You can list the doc fee amount separately below the total if you want, but it must be included in the headline number.

If your listings or DMS are set up to add the doc fee on top of a base price, that needs to change today, not before your next audit.

Your Ads Cover More Ground Than You Think
When the FTC says "advertisement," it means a lot more than a newspaper or TV spot.

Social media. Google and Bing ads. Your VDPs. Third-party listing sites. Radio. Direct mail. And yes, even what your salesperson says on the lot. All of it counts.

If your VDP shows one price and your salesperson quotes a higher one at the door, that is an advertising problem, not just a training problem.

Third-party sites are also your responsibility if you control what shows up there. If you can edit the listing, you own it. The FTC has said more guidance is coming on this, but the basic rule is already clear.

What to Do Right Now
The checklist is short.

First, go through every channel you advertise on. VDPs, Google, Facebook inventory feed, and direct mail. If the price shown is not one a cash buyer can pay today before taxes and government fees, it is not compliant.

Second, build your doc fee into your listed price everywhere. If your system is adding fees to a base price, fix the configuration.

Third, check how MSRP appears on your listings. You can still show the MSRP, but your total advertised price must be more prominent.

Fourth, do not think that leaving the price off protects you. The FTC has been direct about this: not posting a total price at all is itself a deceptive practice.

The Bottom Line
The FTC is not going away. What is happening now is not a short-term enforcement push. Regulators, platforms, and customers all expect pricing to be clear and honest. That expectation is only going to grow stronger.

Dealers who treat this as a one-time fix will keep scrambling every time something changes. Dealers who clean up their pricing and keep it clean will not just stay compliant; they will thrive. They will have an edge.

The Dealers who are hardest to go after are not the ones with the best lawyers. They are the ones with the cleanest operations.