Dealership Compliance Checklist: Advertising, Pricing, and Disclosures

Dealers across the country are asking the same question right now: are our advertising, pricing, and disclosure practices where they need to be given the current regulatory environment?

The FTC’s focus on automotive retail isn’t new, but the scrutiny has intensified. Pricing transparency, financing disclosures, inventory accuracy, and how dealerships communicate with consumers are all areas drawing attention. Dealers who haven’t recently reviewed their practices against current expectations are carrying more risk than they may realize.

This checklist is designed to help dealership teams systematically review the key areas regulators care about most. It is not legal advice, and nothing here should be treated as a determination that your dealership is compliant. Your legal and compliance teams own that assessment. What this checklist does is give you a structured starting point for those conversations.

Work through each section with the relevant teams at your dealership – marketing, finance, digital, and operations – and flag anything that needs deeper legal review.

Section 1: Advertised Vehicle Pricing

Advertised pricing is one of the most active areas of FTC focus in automotive retail. The core question is whether the prices consumers see in your advertising and on your website reflect what they’ll actually pay.

Review each of the following:

☐ Identify all mandatory fees in your market. What fees does every consumer pay regardless of circumstances? Dealer documentation fees, certain government fees, and other unavoidable charges vary by state and market. Work with your legal counsel to identify which fees in your market are mandatory for all consumers.

☐ Audit your advertised prices against your actual transaction prices. Pull a sample of recent deals and compare the advertised price to the out-the-door price before taxes and registration. Are mandatory fees consistently included in your advertised price, or are they added at the transaction stage?

☐ Review your pricing feeds and data sources. How does pricing data flow from your internal systems to your website, third-party listing sites, and digital advertising? Is all-in pricing reflected consistently across every channel, or do different platforms show different numbers?

☐ Check your website inventory pages. Does the price displayed on your VDP reflect the same pricing approach as your paid advertising? Inconsistency between channels creates consumer confusion and compliance risk.

☐ Review how price changes are communicated. When a vehicle’s price changes, how quickly does that update reach your website, paid ads, and listing sites? Stale pricing creates accuracy problems.

☐ Confirm your pricing language is clear. If your advertised price excludes any fees (such as taxes and registration), is that clearly communicated near the price? Is the exclusion presented in a way consumers will notice and understand?

Flag for legal review if: Your advertised prices exclude fees that consumers are required to pay, your pricing varies between channels without clear explanation, or you are uncertain which fees in your market must be included in advertised prices.

Section 2: Financing Disclosures (Regulation Z)

Regulation Z, which falls under the Truth in Lending Act, governs how credit and financing terms must be disclosed when advertised. If your dealership promotes monthly payments, APR offers, or any financing terms in advertising, this section applies.

Review each of the following:

☐ Pull examples of all current financing advertising. This includes paid digital ads, email campaigns, website banners, social media posts, and any other channel where financing terms appear. Review them as a consumer would see them.

☐ Check that APR is disclosed wherever a monthly payment is advertised. A monthly payment figure without the corresponding APR creates an incomplete picture of the credit terms. Reg Z requires APR disclosure when credit costs are advertised.

☐ Verify repayment terms are disclosed. The loan term in months must be clear when monthly payment amounts are advertised. A $349 per month payment means something very different on a 48-month term versus a 72-month term.

☐ Review down payment and amount due at signing disclosures. If a financing offer requires a down payment or any amount due at signing, that information must be disclosed alongside the monthly payment figure.

☐ Check whether any advertised rates are conditional. If a promotional APR is available only to customers with specific credit profiles, or applies only to certain vehicles or terms, those limitations must be disclosed clearly.

☐ Review where disclosures appear relative to the offer. Are Reg Z disclosures presented near the financing offer they qualify for, or are they separated by substantial content, buried in footers, or accessible only through additional clicks?

☐ Audit your email financing disclosures specifically. Financing terms disclosed in email should be directly visible in the email body and not require the reader to click through to a separate page to find material terms.

Flag for legal review if: Any of your financing advertising lacks APR disclosure, loan terms, or down payment requirements; if disclosures require extra clicks to access; or if you are unsure whether your current disclosures satisfy Reg Z requirements.

Section 3: Lease Disclosures (Regulation M)

Regulation M, under the Consumer Leasing Act, governs how lease offers must be presented. Lease advertising involves additional disclosure requirements beyond standard financing, reflecting the complexity of lease structures.

Review each of the following:

☐ Pull all current lease advertising across every channel. Include paid ads, email campaigns, website promotions, and social media content featuring lease offers.

☐ Confirm monthly payment is clearly stated. The advertised monthly lease payment must be clearly disclosed.

☐ Verify amount due at signing is prominently disclosed. This is one of the most significant Reg M requirements. A low monthly payment advertisement without clear disclosure of the amount due at signing creates a misleading impression of the lease’s true cost. The due-at-signing amount must be prominent, not buried.

☐ Check that lease term is disclosed. The number of months in the lease term must be stated clearly in all lease advertising.

☐ Review security deposit disclosure. If a security deposit is required, it must be disclosed.

☐ Confirm the specific vehicle is identified. Lease offers must clearly identify the vehicle or vehicles to which the offer applies. A generic lease payment without vehicle identification doesn’t satisfy Reg M requirements.

☐ Check total payment disclosures. Review whether total lease payment information is included where required.

☐ Evaluate disclosure placement in lease ads. Are Reg M disclosures presented near the lease offer, in readable format, or are they in fine print that consumers are unlikely to notice?

Flag for legal review if: Any lease advertising omits due-at-signing amounts, lease term, or vehicle identification; if disclosures are presented in a way that makes them difficult to notice; or if you are uncertain whether your current lease advertising meets Reg M requirements.

Section 4: Clear and Conspicuous Disclosure Standards

Beyond the specific content required by Reg Z and Reg M, the FTC applies a “clear and conspicuous” standard to disclosures across all consumer communications. This standard asks whether the average consumer would actually notice, read, and understand the disclosure.

Review each of the following:

☐ Review font size and placement of disclosures on your website. Are disclosures presented in a size consumers will actually read? Are they near the claims they qualify, or only in page footers far removed from the relevant content?

☐ Check whether disclosures require extra clicks to access. If material qualifying information is accessible only through a “see details” link or requires additional navigation, evaluate whether that presentation meets the clear and conspicuous standard.

☐ Review disclosure language for plain language compliance. Are your disclosures written in language the average consumer can understand, or are they dense legal text that functionally obscures the information being disclosed?

☐ Audit paid advertising disclosures. For digital ads promoting specific prices or financing offers, review whether required disclosures are present within the ad itself. Relying solely on a landing page for material disclosures may not be sufficient.

☐ Review email disclosure visibility. Are disclosures in your email marketing directly visible in the email body? Email disclosures should not require readers to click through to access material terms.

☐ Evaluate SMS marketing content. If your dealership uses SMS marketing for pricing or offers, evaluate what disclosures are required and whether the format of SMS communications allows for adequate disclosure. This is an area requiring careful legal review given space constraints.

☐ Check for consistency across channels. A consumer who sees your Google ad, visits your website, and then receives an email should encounter consistent pricing and offer information. Inconsistencies across channels create confusion and compliance risk.

Flag for legal review if: Any disclosures require additional clicks to access, are presented in very small font or removed from the relevant claim, are written in language the average consumer would struggle to understand, or if you are uncertain whether any channel’s presentation meets the clear and conspicuous standard.

Section 5: Inventory Accuracy in Advertising

Advertising vehicles that aren’t actually available for purchase, whether because they’ve sold or because the advertised price no longer applies, creates consumer harm and regulatory exposure.

Review each of the following:

☐ Understand how sold vehicles are removed from advertising. When a vehicle sells, how quickly are ads for that vehicle paused across all channels, including your website, paid search, display advertising, social media, and third-party listing sites? Manual processes create windows of inaccuracy.

☐ Check for inventory validation in your advertising workflows. Before vehicles are included in paid advertising campaigns, is there a process to verify they are actually available in current inventory?

☐ Review how pricing changes propagate. When a vehicle’s price changes, how quickly does that update flow to all advertising channels? Delayed propagation means ads may run with outdated pricing.

☐ Audit your listing site feeds. Third-party inventory sites often run on feed update schedules. Understand how frequently your feeds update and whether sold vehicles are removed promptly.

☐ Check whether offer-specific advertising accurately identifies inventory. Special pricing offers, certified pre-owned promotions, or other vehicle-specific offers should clearly identify the specific vehicles they apply to.

Flag for legal review if: You don’t have a clear process for removing sold vehicles from advertising promptly, if inventory validation doesn’t occur before vehicles are included in paid campaigns, or if you’ve experienced situations where advertising ran for sold or incorrectly priced inventory.

Section 6: Consumer Communications

FTC consumer protection principles extend to the full scope of how dealerships communicate with consumers beyond formal advertising, including email marketing, SMS campaigns, and online chat interactions.

Review each of the following:

☐ Review promotional language in email campaigns. Does marketing language accurately represent what you’re offering? Are urgency claims (limited time, limited inventory) accurate? Is pricing language consistent with your advertised pricing practices?

☐ Check consent practices for SMS marketing. Are you collecting appropriate consent before sending marketing SMS messages? Consult your legal team on applicable requirements.

☐ Review AI chat and chatbot interactions. If your dealership uses AI-powered chat tools, review how those tools handle pricing questions, financing inquiries, and offer information. Does the information provided through chat align with your advertised pricing and disclosure practices?

☐ Evaluate the consistency of information across channels. Pricing, offer terms, and vehicle availability information presented through chat, email, or SMS should be consistent with what appears in formal advertising.

☐ Review how consumer inquiries about pricing and terms are handled. When consumers ask about pricing or financing terms through chat or email, are responses accurate and consistent with your advertised information?

Flag for legal review if: Any communication channel is presenting pricing or offer information that is inconsistent with advertised terms, if consent practices for SMS marketing need review, or if AI chat tools are providing information about pricing or financing that hasn’t been reviewed for accuracy and consistency.

Using This Checklist

This checklist is a starting point, not a finish line. Work through each section with the relevant teams at your dealership. Document what you find, both the practices that appear sound and the areas that need further review or correction.

Bring flagged items to your legal and compliance team with specific examples. “Our email financing disclosures require a click-through to access terms” is a more actionable conversation starter than “we think our emails might have compliance issues.”

Create a process for ongoing review. Advertising practices, pricing approaches, and technology platforms change. A one-time audit is valuable, but the dealerships that manage compliance most effectively build regular review into their operations rather than treating it as a periodic project.

None of the items in this checklist constitute a legal determination about your dealership’s compliance. That assessment belongs to qualified legal counsel who understands your specific market, practices, and applicable regulations. This checklist helps you identify what to bring to that conversation.

Fullpath is actively reviewing evolving FTC expectations and making platform enhancements to better support dealers across advertising, offers, pricing, and consumer communications. Fullpath already has several safeguards in place today, including the ability to validate that vehicles are actively in inventory before advertisements are enabled or distributed, all-in pricing pulled directly from dealer-provided feeds, and automated reviews for deceptive claims in advertising copy. Fullpath is continuing to build stronger workflows, validation, and disclosure controls to help reduce dealer risk exposure while maintaining a strong consumer experience. Schedule a demo to learn more.

Questions? Contact us: get.started@fullpath.com

This article is provided for general informational purposes only and does not constitute legal advice. Dealerships should consult with qualified legal counsel regarding their specific compliance obligations.