Can I advertise a price that requires financing with the dealer?

Not as the advertised price. The March 2026 warning letters list "conditioning the advertised price on consumers using dealer financing" as an illegal practice. You can show a dealer-financing discount as long as the price any buyer would pay with any financing is the most prominent number. The FTC's example: a $39,999 car with a $2,000 financing discount, where $39,999 leads.

Is the FTC price transparency FAQ a rule?

No. The document states that it "represents the views of FTC staff and is not binding on the public or the Commission." The CARS Rule, which would have been binding, was withdrawn on February 12, 2026. The FAQs describe how staff read Section 5 of the FTC Act, which is what the warning letters and lawsuits rest on.

What happens if I get an FTC warning letter?

The March 13, 2026 letters to 97 auto groups asked dealers to review their advertising and pricing practices and make sure advertised prices include all fees consumers must pay, and said the FTC would keep monitoring and take additional action as warranted. A letter is not a lawsuit, but treat it as a deadline to fix the site, feeds, and scripts, and document what you changed.

Who is responsible when a listing site shows the wrong price?

Everyone who controls the ad. FAQ 12 says dealers should provide the actual price and "take all steps within their control to ensure that the third party discloses it as the most prominent amount," and third-party advertisers should make sure that price appears most prominently. Put the doc fee inside the price field of your feed and check how each site renders it.

Do "starting at" prices comply with the FTC FAQs?

Only if a customer can actually buy the car for that number. The FAQs require that "any advertised price must reflect the actual price that any consumer can pay to purchase the car," and that it be the most prominent amount on the page. A "starting at" figure no buyer can pay, or that excludes a mandatory fee, fails that test.

FTC Price Transparency FAQs: What Car Dealers Must Do (2026)

Q: Does the advertised price have to include the doc fee?

Yes, if any customer is required to pay it. The FTC FAQs say "the advertised price must include any mandatory fee, including the full document fee if the dealer requires any consumer to pay it." Their example: a $40,000 car with an $85 doc fee is advertised at $40,085. If some buyers are quoted a higher mandatory fee, the higher fee goes in the number.

Short answer: the FTC's September 15, 2026 price transparency FAQs say an advertised price must be the price any consumer can walk in and pay, excluding only government-required charges. A mandatory doc fee goes inside the number. They are non-binding staff views that describe how the FTC Act is enforced.

If you run an independent lot, this is the year the advertised price stopped being a marketing decision and became a compliance one. In March the FTC sent warning letters to 97 dealer groups. In July, CarGurus began pushing used listings without disclosed fees down its search results. In August the FTC and Connecticut settled with a dealer for $4 million over fees. Then on September 15 the FTC published 14 FAQs that spell out what it expects in every ad, listing, text, and phone call.

None of this changes the law. Section 5 of the FTC Act has prohibited deceptive advertising for decades. What changed is that the FTC wrote the standard down. This guide covers what the FAQs say, the timeline, what each channel needs, and the two places most independent dealers slip: the vehicle detail page and the first reply to a lead.

The FTC Price Transparency FAQs, Explained

The Automobile Industry Pricing Transparency FAQs are a 14-question document FTC staff published in September 2026 to help dealers, third-party advertisers, and manufacturers comply with the FTC Act. The core rule, in the FTC's own words: "the FTC Act requires that the advertised price be the actual price any consumer can walk in and pay. In other words, if a dealer requires a consumer to pay a fee to purchase the car, that fee must be included in the advertised price."

The only thing a dealer may leave out is what the FAQs call government-required charges, "i.e., amounts a Federal, State, or local government agency requires the consumer to pay directly." Everything else goes in, including "dealer-required fees that governments authorize but do not mandate." That covers the doc fee: "The advertised price must include any mandatory fee, including the full document fee if the dealer requires any consumer to pay it." The FTC's example is a $40,000 vehicle with an $85 doc fee, which must be advertised at $40,085.

The document carries a caveat that matters: "Please note that this document represents the views of FTC staff and is not binding on the public or the Commission." It is guidance, not a rule, but it comes from the agency that sends the warning letters, and the September 15 press release adds that "the FTC continues to bring lawsuits against auto dealers that mislead consumers by advertising one price only to end up charging higher amounts."

How we got here: a dated timeline

Each step below is a public FTC or platform action, with the source linked.

Date	Event	Source
January 2024	FTC and Connecticut sue Chase Nissan LLC (Manchester City Nissan) over fees and add-ons.	FTC, Aug 19, 2026
February 12, 2026	FTC withdraws the Combating Auto Retail Scams (CARS) Rule after federal court decisions. The FTC Act still governs dealer ads.	Federal Register
March 13, 2026	Warning letters to 97 auto groups, listing six illegal pricing practices.	FTC press release
June 24, 2026	CarGurus: from July 14, used inventory without disclosed fees is marked "No Rating" and moves lower in search results.	CarGurus dealer blog
August 19, 2026	$4 million FTC and Connecticut settlement with Manchester City Nissan. The order requires the maximum total price, excluding only required government charges, to be the most prominent item.	FTC press release
September 15, 2026	FTC staff publish the 14 price transparency FAQs.	FTC press release

FAQ 13, on how long dealers have to comply, answers: "Price transparency is not a new requirement."

What the FAQs require, channel by channel

FAQ 3 is the one most dealers miss. It lists "dealership or third-party websites, social media, print advertisements, roadside signs, or even phone calls and text messages with a dealer's staff," and "Regardless of the format, every one of these touchpoints is subject to the FTC Act." A text from your BDC is an advertisement. FAQ 12 settles who answers for it: "everyone who has control over the advertising is responsible for making sure the ads state the actual price as the most prominent amount."

Channel	What the FAQs require	Who is responsible
Website SRP and VDP	On "inventory-search pages and individual-vehicle-listing pages," the actual price "must be listed as the most prominent amount" (FAQ 4). MSRP and discounts only if less prominent (FAQ 5).	The dealer, and the website provider rendering the page.
Third-party listing sites	Same standard. The dealer must "provide the actual price and take all steps within their control to ensure that the third party discloses it as the most prominent amount" (FAQ 12).	Dealer for the feed; the site for the display.
Social and search ads	Any price shown is the price any consumer can pay, with no discount "only available to a subset of buyers" baked in (FAQ 9).	The dealer and whoever builds the ad.
First text or email reply	A text with dealer staff is a covered touchpoint (FAQ 3). The figure quoted is the advertised figure, not a lower teaser or a "plus fees" number.	BDC, salespeople, and any AI assistant replying for the dealer.
Phone script	Phone calls are named in FAQ 3. "Dealers should make sure no one at the dealership provides any contradictory instructions" (FAQ 12).	Everyone who answers the phone.

What to change on your website

Your website is the one channel you fully control, so it is where the standard is easiest to meet and easiest to prove. Walk your own SRP and VDP as a shopper and check these.

1One price, most prominent. On every page that shows an amount, the price any buyer can pay is the largest and clearest number. FAQ 5 warns that "Prominence is not limited to font size": a smaller MSRP placed where the eye lands first still fails.
2Doc fee inside the price. If any customer pays a doc fee, the advertised price includes it in full. If some customers are quoted a higher mandatory fee, FAQ 6 says the higher fee is the one built in.
3Conditional discounts secondary and labeled. The FTC's example is a $39,999 vehicle with a $2,000 dealer-financing discount, where $39,999 is the number that leads and the terms are clear.
4No hidden required add-ons. FAQ 9: dealers "cannot suggest an add-on is required when it is in fact optional." A mandatory package is in the advertised price; an optional one is labeled optional.
5In-transit and offsite cars flagged, sold cars removed. FAQ 10: if a car is not physically on the lot, "the ad must plainly state that fact."
6Real photos for used cars. FAQ 11: "it is reasonable for consumers to expect the photo to show the exact car offered for sale."

The usual failure is not bad intent. It is the DMS, the website, and the listing feed disagreeing because a fee was edited in one place and not the others. The fix is one source of truth for the price, doc fee built in, feeding every page and feed. Get My Auto dealer websites pull real-time pricing updates from the DMS and syndicate the same inventory to Google, Craigslist, Facebook, and CarGurus with one click, so the VDP and the marketplace read from the same record. If you are evaluating any provider, our guide to choosing a car dealer website provider covers what to ask, and the websites for auto dealers page shows how the DMS-to-website sync works.

Third-party listings and the CarGurus deadline

Marketplaces moved before the FAQs did. On June 24, 2026 CarGurus told dealers that "prices they advertise should be the total price, including all mandatory fees, that a consumer is required to pay," and that "Starting July 14, any used inventory on our platform without disclosed fees will be categorized as 'No Rating'" and "will move lower in search results" (CarGurus dealer blog). That is a ranking penalty on top of the legal exposure.

The FTC does not treat a wrong listing as the site's problem alone. Under FAQ 12 the dealer supplies the actual price and takes every step within its control to have the site show it most prominently. Carry the doc fee inside the price field of your feed, and spot-check your listings weekly the way a shopper sees them.

Dealership BDC agent texting a car shopper from the showroom floor with vehicles in the background — The first reply to a lead is an advertisement under the FTC FAQs. The number in the text has to match the number on the listing.

The first reply must match the ad

Picture it from the buyer's side. A shopper sees a car listed at $24,999, texts in, and the reply says "$24,999 plus doc fee and dealer prep." Or the rep on the phone says "that price is with our financing." Under FAQ 3 that text and that call are advertisements, and under FAQ 9 the buyer "has been misled" if the number quoted on arrival is higher than the number in the ad. For a small store the exposure sits with whoever answers the first text, whoever answers the phone, and any automated reply. The fix is a script and a record.

Quote the advertised price, exactly, in the first reply. Taxes and government fees are the only additions, and you say so.
Never condition the advertised price on financing. Present the unconditioned price first and any financing discount second, with its terms.
Call optional add-ons optional. A required, installed package is already in the price you quoted.
Log every conversation. If a letter or complaint arrives, the recorded call and text thread show the reply matched the ad.
Give the same instructions to every person and every tool that replies. FAQ 12 says no one at the dealership should give contradictory instructions.

This is where an AI assistant helps or hurts depending on how it is built. Ava, the AI BDC inside the Get My Auto CRM, pulls from your real-time inventory and sends the shopper the listing link for the exact car they asked about, so the shopper sees the listing price. Every call, text, and email is recorded on the lead, and managers can listen to recorded calls: that is your audit trail. What no software can do is set your price policy. Decide whether the doc fee is in the number, load it once, and let every channel read from it. More on how Ava handles pricing and fee questions on the AI for auto dealers page, and on the accuracy standard for AI-generated claims in our AI governance guide for dealers.

Not legal advice. This article summarizes public FTC staff guidance and press releases as of September 28, 2026. The FTC itself notes that "the net impression of any given advertisement always turns on the specific circumstances of that advertisement," and state doc fee laws add their own disclosure rules (FAQ 7). Talk to a dealer compliance attorney about your own ads.

How Get My Auto fits

The FTC standard is simple to state and hard to keep when the price lives in four systems. Get My Auto is one platform: the DMS holds the price, the website reads it in real time, the same inventory syndicates to Google, Craigslist, Facebook, and CarGurus, and the CRM logs every reply. The DMS also carries compliance monitoring for FTC, state, and federal requirements.

The CRM and Ava together are $695 a month with a 60-day free trial, and you can start the trial without a demo. Dealer websites and the DMS are demo-priced, so if the website is where your price problem lives, request a demo and bring a screenshot of your current VDP. We will show where the price comes from and how the doc fee gets built in once.