If you haven't heard yet, here's news that should get your attention: on March 13, 2026, the Federal Trade Commission announced that it sent warning letters to 97 auto dealership groups across the country, putting them on notice about deceptive pricing practices. This is not a routine advisory — it is a direct signal that the FTC is actively monitoring the auto retail industry and is prepared to take enforcement action.

What the FTC Did — and Why It Matters The FTC sent letters to 97 auto groups nationwide, warning them that advertised prices must represent the total price — including all mandatory fees — that consumers will actually be required to pay. While these letters are not formal complaints or lawsuits, they are the step that typically precedes them. It also signals that the FTC explicitly will continue to monitor the marketplace broadly. The CARS Rule may be dead, but the FTC still has authority to regulate advertising practices under its broad ability to regulate unfair and deceptive practice.

The letters were signed by Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, who made the agency's intent unmistakably clear: the FTC will remain focused on monitoring auto dealerships to ensure that the market functions efficiently and that competitors are transparently competing on price.

What Practices Are in the Crosshairs? The warning letters spell out specific conduct the FTC considers illegal. Every used car dealer should review this list carefully against their own advertising and sales practices. According to the letters, illegal pricing practices include:

• Advertising a price that does not reflect all required fees
• Advertising a price based on rebates or discounts not available to all consumers
• Advertising a price that fails to account for an additional required down payment
• Conditioning the advertised price on the consumer using dealer financing
• Requiring consumers to purchase additional items not reflected in the advertised price
• Advertising vehicles that are unavailable or do not exist

The FTC's core rule is straightforward: the price a consumer sees in your advertising should be the price they actually pay — with the only permissible exclusion being required government charges like taxes and registration fees. Everything else must be included.

There Are Active Cases — and They Are Getting Results This is not theoretical. The FTC cited several pending enforcement actions in the letters, including cases against Lindsay Chevrolet, Leader Automotive Group, and Asbury Automotive Group. These cases allege dealers advertised prices they refused to honor, added hidden charges, required consumers to purchase pre-installed products, and misrepresented financing terms. Federal courts are the venue, and the reputational and financial exposure in these cases is substantial.

The FTC has also made clear that auto dealer pricing is part of a broader enforcement campaign. The agency has pursued price transparency actions across rental housing, ticketing, hotels, and grocery delivery services — the auto industry is simply the latest focus, not the last.

What You Should Do Right Now Do not wait for a letter to arrive. The time to act is before the FTC comes to you. We recommend that every dealer take the following steps immediately:

Audit your advertising. Pull every current advertisement — website listings, thirdparty platforms, print, social media — and compare the advertised price to the actual out-the-door price. If there is a gap created by mandatory fees, add-ons, or financing conditions, your advertising needs to change.

Review your add-on and F&I practices. Products that are required of all buyers must be reflected in the advertised price. Products that are truly optional must be presented and documented as such, with clear consumer acknowledgment and not added onto closing documents without the consumer’s consent.

Train your staff. Sales and finance personnel need to understand that advertising compliance is not just a marketing department issue — it runs through every customer interaction.

Document your compliance efforts. If the FTC does come knocking, a documented, goodfaith compliance review conducted before contact is a meaningful mitigating factor.

The Bottom Line The FTC has announced publicly that it is watching the industry. Warning letters are the last off-ramp before formal investigation and litigation. The legal standard — advertised price equals actual price — is not ambiguous. Compliance is not difficult if your practices are straightforward; it simply requires discipline and internal review.

If you have questions about whether your current practices put you at risk, or if you have received one of these letters, please contact MidAtlantic immediately. Do not ignore this. The dealers who respond proactively are the ones who stay out of court.