Industry Alert: FTC Enforcement on Vehicle Advertising & Dealer Fees
April 6, 2026
The Utah Automotive Alliance (UAA) and Independent Dealer Solutions (IDS) is issuing this important industry alert regarding recent enforcement actions and guidance from the Federal Trade Commission (FTC) related to vehicle advertising practices and dealer-imposed fees.
In March 2026, the FTC issued warning letters to dozens of dealerships nationwide reinforcing a clear standard: advertised vehicle pricing must include all mandatory fees, with only government-imposed charges (such as taxes, title, and registration) permitted to be excluded.
This guidance is not theoretical. The FTC, in coordination with state regulators, recently announced a major enforcement action against a dealership group for deceptive pricing practices, including:
Advertising prices that did not reflect the true cost to consumers
Adding undisclosed fees at the dealership
Advertising rebates not available to all buyers
Charging for add-on products without proper consent
The result included tens of millions of dollars in consumer restitution, civil penalties exceeding $3 million, and individual executives named personally in enforcement actions.
What This Means for Utah Dealers
The FTC has made it clear that the following practices are considered unlawful and subject to enforcement:
Advertising a price that does not include all required fees, including dealer documentary or service fees
Advertising rebates or discounts that are not available to all consumers
Failing to disclose required down payments or trade-in conditions tied to an advertised price
Conditioning an advertised price on the use of dealer-arranged financing
Requiring the purchase of add-on products not included in the advertised price
Advertising vehicles that are not actually available
Charging for add-on products or services without the consumer’s clear, informed consent
Utah Regulatory Alignment
The Utah Automotive Alliance has engaged with the Motor Vehicle Enforcement Division (MVED), the Utah Division of Consumer Protection, and other compliance experts regarding these developments.
State regulators have reinforced the FTC’s position:
"Through recent enforcement actions, the FTC emphasized that the 'total advertised price' includes all mandatory charges, excluding only government-mandated fees and taxes. The Division has repeatedly warned that the advertised price must reflect what a buyer will actually pay: mandatory fees must be included in the advertised price, and any add-ons must be truly optional. The Division is committed to enhancing trust and ensuring a level playing field in Utah's auto industry. We will hold accountable those who seek to undermine the market and harm consumers through deceptive practices."
— Utah Division of Consumer Protection
Immediate Action Steps for Dealers
To ensure compliance and reduce risk, UAA strongly recommends that all dealers immediately:
Review all advertising (website, third-party listings, social media, print, and radio) for pricing accuracy
Ensure all mandatory dealer fees are included in advertised prices
Clearly disclose any conditions tied to pricing (financing, trade-in, rebates)
Eliminate pre-selected or bundled add-ons that are not optional
Train sales and F&I staff on consent requirements for all products
Audit inventory listings to confirm advertised vehicles are available
Work with legal counsel or compliance providers to review advertising practices
These changes represent a significant shift in enforcement—not just guidance. Regulators are prioritizing pricing transparency, and dealerships that fail to comply face substantial financial and legal exposure.
The Utah Automotive Alliance remains committed to representing and protecting Utah dealers. We will continue to monitor developments and provide guidance as needed.
If you have questions or would like assistance reviewing your dealership’s advertising practices, please contact the Utah Automotive Alliance.
Sincerely,
Adam Jones
Executive Director
Utah Automotive Alliance