What the FTC’s New Pricing Guidance Means for Dealer Products 

Dealers have spent months trying to determine what increased Federal Trade Commission scrutiny means for advertised vehicle prices, F&I products, addendums, and products already installed on a vehicle. 

On September 15, FTC staff provided more detail with its Automobile Industry Pricing Transparency FAQs, following warning letters sent earlier this year to 97 auto groups. 

The guidance reiterates that an advertised vehicle price should be the price any consumer can pay, excluding only charges the government requires the consumer to pay. 

For dealers offering F&I, protection, connected-vehicle, and other products, the FAQs also clarify another issue: dealers may continue offering optional products as long as customers are not misled about whether those products are required, what they cost, or whether the customer agreed to buy them. 

For the store, the key question is how the product enters the deal. 

What the FTC Says About Advertised Vehicle Prices 

The FTC’s March warning letters identified several practices the agency was scrutinizing. Those included mandatory fees omitted from advertised prices, prices conditioned on dealer financing or a down payment, discounts unavailable to every customer, and required products that were not reflected in the advertised price. 

The September FAQs provide more detail. 

If a dealership requires a customer to pay a charge in order to purchase the vehicle, FTC staff says that charge generally needs to be included in the advertised price. That includes a mandatory document fee. 

If an advertisement also shows MSRP, rebates, or conditional discounts, the price any consumer can actually pay should remain the most prominent amount. 

FTC staff says the same principles apply beyond dealership websites, including third-party listings, social media, print advertising, signs, phone calls, and text messages. 

For dealership leadership, this is a consistency issue. A shopper should not see one price online, hear another from the salesperson, and encounter a third when the deal reaches the desk or F&I office. 

Read the FTC’s March warning to 97 auto groups 

What This Means for Optional and Preloaded Products 

Dealers can still offer protection packages, accessories, F&I products, and other goods and services. 

The compliance issue is how those products are represented and charged. 

Problems arise when an optional product is presented as required, when an installed product is described as something the customer must purchase even though that is not true, when the price is misstated, or when the customer is charged for something they did not agree to buy. 

That matters in particular for products installed or preloaded before the vehicle is sold. Installation by itself does not determine how the product enters the transaction. 

A dealership can include the product at no additional customer charge, offer it as an optional paid product, or require the customer to pay for it as part of the vehicle purchase. 

If the product is optional, employees should not tell customers they must pay for it simply because it is already installed. FTC staff specifically addresses claims that an installed option cannot be removed and therefore must be purchased when that is not actually the case. 

If the dealership requires the customer to pay for the product to purchase the vehicle, FTC staff says that dealer-required charge generally needs to be reflected in the advertised vehicle price. 

Providing the product at no additional charge is another possible business model, but the FAQs do not require dealers to give products away. 

The store should decide before the customer conversation whether the product is included, optional, or required as part of the purchase. Advertising, sales, F&I, documentation, and delivery should all follow that same approach. 

NADA Had Been Signaling the FTC’s Pricing Focus 

The FAQs are consistent with comments NADA President and CEO Mike Stanton made before their release. 

In an August industry interview, Stanton said NADA had met with the FTC several times while the agency prepared the FAQs. He described the agency as: 

“laser focused on that price.” 

He also distinguished the current effort from the much broader Vehicle Shopping Rule: 

“This is just about the price.” 

Stanton connected pricing transparency with the dealership customer experience and said NADA believed the direction could ultimately benefit the industry. 

After the FAQs were released, NADA called them an important step toward clearer advertising-compliance guidance and said the association had worked with dealers and the FTC to address questions stemming from the warning letters. 

Mike Stanton discusses NADA’s conversations with the FTC, the agency’s pricing focus, and what greater pricing transparency could mean for dealers. 

The FAQs also have limits. The FTC says they represent FTC staff views, are not binding on the public or the Commission, and cannot address every fact-specific advertising situation. 

Customer Authorization and Training Still Matter 

Pricing is only part of the issue. 

In August, the FTC and the state of Connecticut secured a $4 million settlement with Manchester City Nissan and related defendants involving allegations that included deceptive pricing and unauthorized charges. Regulators alleged that some charges, including total-loss protection, were inserted into financing agreements without consumers’ knowledge or consent. 

The customer should leave the store understanding the deal the same way the dealership does. If the store considers a product optional but the customer leaves believing it was required, the process failed somewhere. 

Written policy alone will not prevent that. 

At the June CBT News Fair Pricing & Compliance Summit, attorney Barrie Charapp Beaty emphasized that employees need to understand the products they sell and know how to explain them. Marco Schnabl of RockED similarly stressed the need for employees to know the products and be prepared for the customer conversation. 

Employees need to know what the product costs, whether the customer has a choice, what they are authorizing, and how that decision needs to be documented. 

Read the FTC’s Manchester City Nissan settlement announcement 

Where CarRx Fits 

For CarRx dealer partners, the same framework applies. 

CarRx can remain useful after the original transaction. Depending on the vehicle and plan, customers can access vehicle information, maintenance and service support, and available security-related features. 

For a store using CarRx as a preloaded solution, the dealership should decide how the plan enters the deal before employees present it to customers. 

If CarRx is an optional paid product, the customer should understand both the choice and the price. 

If the dealership provides CarRx at no additional charge, the customer can still receive and use the product after delivery. 

If the dealership requires the customer to pay for CarRx as a condition of purchasing the vehicle, its legal and compliance team should review how that charge is reflected in the advertised vehicle price under the FTC guidance. 

Whatever model the dealership chooses, the customer-facing process should match it. 

Learn more about CarRx for dealerships 

CarRx can also give the dealership a reason to stay connected with customers after the vehicle leaves the lot. Drivers can receive vehicle and maintenance information that can help bring them back to the dealership when service is needed. 

See how CarRx supports customer lifetime value after the sale 

Activation Matters at Delivery 

If CarRx is part of the deal, delivery is where the customer can see what they received and begin using it. 

Activating CarRx during delivery gives dealership employees an opportunity to show the features available with the customer’s plan, help the customer become familiar with the app, and explain how CarRx can be used after the vehicle leaves the store. 

That connects the product conversation to something the customer can immediately see and use. It also gives the dealership a chance to establish how CarRx fits into future vehicle information, maintenance, service support, and other available features. 

Transparent Pricing Changes What Dealers Compete On 

The FTC also frames pricing transparency as a competition issue. 

Its FAQs describe the disadvantage created when one dealer advertises a price a customer can actually pay while another advertises a lower number the customer cannot obtain. FTC staff says that practice makes meaningful comparison shopping more difficult and disadvantages dealers advertising truthful prices. 

When advertised prices are easier to compare, dealers have more reason to differentiate through the buying process, legitimate products, service after the sale, and the ongoing customer relationship. 

A product such as CarRx has to earn its place in that environment by giving the customer something useful after the transaction. 

“Clearer pricing can be good for dealers that are focused on creating a better customer experience. When the price is straightforward and the product provides real value, dealers can spend less time explaining surprises in the transaction and more time showing customers what they’re actually getting.” 

Shane Wilson, President, CarRx 

Dealers Can Keep Offering Products, but the Process Matters 

The FTC’s September FAQs give dealers more detail, but they do not replace dealership-specific legal and compliance review. 

For dealer products, the practical direction is clearer. Stores need to know how each product is priced, how it is presented, whether the customer has a choice, how authorization is captured, and whether the documentation matches what the customer was told. 

For CarRx dealer partners, that starts with deciding how the product fits into the transaction before employees begin presenting it. 

By delivery, the customer should understand what they purchased, what they paid, whether they had a choice, and what the product does after the sale. The dealership should be able to document the same story. 

This article is intended for general educational and informational purposes only and is not legal advice. The FTC’s September 2026 FAQs represent FTC staff views and are not binding on the public or the Commission. Dealerships should consult their own legal and compliance professionals regarding advertising, pricing, product presentation, customer authorization, documentation, and applicable federal, state, and local requirements.