FTC Dealer Fee Disclosure: What Every Car Dealer Must Know in 2026
Millions in fines. Real dealers. A clear fix. Here is what you need to understand before the FTC shows up at your store — and the one technology tool that makes staying clean straightforward.
Quick Summary: What Is Actually Happening Right Now
I have been doing this for over twenty years. I have three kids. I drive a truck. I live in West Virginia and I have spent the better part of two decades sitting across from dealers who work sixty-hour weeks trying to do right by their families, their staff, and their customers. So when I tell you the FTC is now fining dealerships millions of dollars for hiding fees in their advertised prices, I am not saying it to scare you. I am saying it because somebody has to tell you the truth, and I would rather it come from me than from a federal complaint with your store's name on it. If your advertised price does not include every mandatory fee your customer will pay — except taxes, tags, and title — you are in violation. That is the whole rule. The details get complicated. But that sentence is the one you need to tape to your monitor.
What
When
Status
Your Risk
CARS Rule Finalized
Dec 12, 2023
Vacated
Historical only
Fifth Circuit Vacates CARS Rule
Jan 27, 2025
Rule Killed
Enforcement remains
Honda of Bowie Settlement
March 2025
$3M Penalty
Public. Documented.
Lindsay Automotive Settlement
April 2, 2026
$3.1M + $75M Refunds
Largest recent action
FTC Warning Letters — 97 Groups
March 13, 2026
Active Warning
1,000+ locations
Section 5 FTC Act Enforcement
Ongoing 2024–2026
In Full Force
High — no rule needed
S&P Global FeeSync Launch
May 27, 2026
Live & Free
Industry infrastructure
🚨 The Bottom Line
The FTC does not need the CARS Rule to come after your store. Section 5 of the FTC Act has been law since 1914. It says you cannot run deceptive advertising. Hiding a $999 processing fee in fine print while advertising a $30,000 price is Section 5. That is why Honda of Bowie paid $3 million.
The Real Case: What Honda of Bowie Did Wrong
This is not a hypothetical. In March 2025, the Maryland Attorney General's Office announced a settlement with Honda of Bowie, a dealership operating in Prince George's County, Maryland. The dealership paid a $3 million civil penalty. Consumers who bought or leased vehicles from January 2019 through May 2022 were notified they may be owed refunds. The violations were not complicated. They were brazen.
"The dealership charged thousands of customers a 2% 'sales commission' fee that was labeled as 'optional' but was not actually optional — and did not compensate any salesperson."
— Maryland Attorney General Settlement, March 2025 (Public Record)
Three Violations That Cost $3 Million
1
The Fake "Optional" Commission Fee
A 2% fee appeared on every deal. It was labeled "optional." It was not optional. No customer was told they could decline it. It did not go to any salesperson. This single practice became the centerpiece of the case.
2
Advertised Price Did Not Match Transaction Price
Cars were listed online at prices that did not include mandatory markups. The customer saw $32,000 on the listing. They sat down at the desk and the number was $34,500. That gap is the violation.
3
Add-Ons Without Clear Consent
Service contracts and protection packages appeared on buyer's orders that consumers did not knowingly agree to. Some customers were told these were required. They were not.
Transparency between listed price and transaction price is now a federal enforcement priority.
The Lindsay Automotive Group: The Bigger Warning
In April 2026, the FTC and Maryland AG announced a settlement covering over $75 million in potential consumer refunds and a $3.1 million civil penalty against Lindsay Automotive Group, which operated three Virginia and Maryland stores. The finding: 88% of consumers who purchased between 2020 and 2023 paid an average of $2,000 more than the advertised price.
⚖️ What These Settlements Require Going Forward
All mandatory fees in every advertised price. Express written consent before any charge. Total price disclosed in every consumer communication — excluding only taxes, registration, and title.
The CARS Rule Is Dead. The FTC Is Not.
Here is where most dealers get confused. The Fifth Circuit Court of Appeals vacated the CARS Rule on January 27, 2025. The rule never spent a single day as enforceable law. So you thought you were safe. You were not.
CARS Rule Requirement
Status Without CARS Rule
All mandatory fees in advertised price
Still enforceable via Section 5
Clear total offering price disclosure
Still enforceable via Section 5
No bogus add-ons
Still enforceable via Section 5
Express consumer consent before charges
Still enforceable via Section 5
No bait-and-switch pricing
Still enforceable via Section 5
Everything the CARS Rule was going to codify was already illegal under Section 5 of the FTC Act. Section 5 prohibits "unfair or deceptive acts or practices" and has been on the books since 1914. On March 13, 2026, the FTC sent warning letters to 97 dealer groups covering more than 1,000 locations, making clear that advertised prices must include all mandatory fees or face federal action. That is a published FTC press release, not a rumor.
📌 What the March 2026 FTC Letters Said
Dealers were warned against: advertising prices without mandatory fees included; advertising rebates not available to all buyers; conditioning the price on dealer financing; requiring undisclosed add-ons; and advertising unavailable vehicles.
The Problem Every Owner and GM Actually Has
I talk to owners and GMs every week. Good people. People who coach little league and sponsor the local 4H and know every service advisor by name. Here is what I hear: "Halsey, we comply on our website. Our prices are right there." Then I ask: "What about AutoTrader? CarGurus? Facebook Marketplace? The OEM site? Email blasts?" That is where the silence starts. And that silence is exactly what the FTC is listening for.
Your inventory does not live in one place. It lives in twenty, thirty, sometimes fifty places simultaneously. Every one of those places is an advertisement. The FTC does not care where the consumer saw the price. If they saw a price without your processing fee, that is a deceptive advertisement.
Channel
FTC Compliance Required?
Feed-Controlled?
Dealer Website
Yes
Usually
AutoTrader / Cars.com
Yes
Yes — via inventory feed
CarGurus
Yes
Yes — via inventory feed
Facebook Marketplace
Yes
Yes — via inventory feed
OEM / Manufacturer Site
Yes
Varies by OEM
Email Campaigns
Yes
Manual — high risk
Google Vehicle Ads
Yes
Yes — via inventory feed
The owner reading this right now is thinking: "OK — how do I make sure the same fee-inclusive price appears everywhere, every time?" That is the right question. The answer is your inventory syndication platform.
How HomeNet Solves the Multi-Channel Pricing Problem
HomeNet Automotive's Inventory Online (IOL) platform is an inventory merchandising and syndication tool. You define your prices — with fees baked in — and HomeNet pushes them to thousands of advertising destinations simultaneously. One source. One price. Everywhere. That is the compliance win.
1
Define Your Fee Structure in Your DMS Classify every fee: mandatory (goes in the advertised price) or optional (disclosed separately at point of sale). Only taxes, tags, and title stay out of the advertised price.
2
Calculate the All-In Price Your DMS or pricing system adds mandatory fees to the base price. If vAuto recommends $32,000 and your mandatory processing fee is $699, your advertised price is $32,699. That is the number that leaves your system.
3
HomeNet Pulls the Compliant Price via API HomeNet connects to your DMS and pricing system. The fee-inclusive price flows in automatically whenever it updates.
4
HomeNet Syndicates to Every Channel That single fee-inclusive price goes to your dealer website, AutoTrader, Cars.com, CarGurus, Facebook Marketplace, Google Vehicle Ads, and every other destination your HomeNet account feeds — same price, every channel, no manual updates.
5
Price Changes Propagate Automatically When you change a price, the update flows through the same pipeline. You touch one place. HomeNet handles the rest. That automatic consistency is where FTC risk lives — and where HomeNet eliminates it.
✅ May 2026 Validation: S&P Global FeeSync
On May 27, 2026, S&P Global Mobility launched FeeSync — a free, industry-wide platform for centralized fee data management and API syndication to vendor partners. The announcement explicitly stated that dealers currently lack centralized fee management and are forced to manually update dozens of vendor platforms. HomeNet already solves this architecturally. The industry is building toward what HomeNet already does.
HomeNet vs. vAuto: Not the Same Thing
Here is the clearest way to put it: vAuto tells you what to charge. HomeNet tells the world what you are charging. The FTC violation happens in the gap between those two. You need both — but for compliance, HomeNet is the layer that matters.
Capability
HomeNet
vAuto
Market-Based Pricing Intelligence
✗ Not primary
✓ Core function
Inventory Stocking & Acquisition
✗
✓ Core function
Multi-Channel Inventory Syndication
✓ Core function
✗ Not primary
Centralized Fee-Inclusive Distribution
✓ Configurable
✗ Downstream only
Photos & Video Syndication
✓ Core function
✗
FTC Advertising Compliance Coverage
✓ Direct
✗ Pricing layer only
Compliance Audit Trail
✓ Via feed records
✗ Not designed for
Best practice: Use vAuto for market intelligence and pricing strategy. Add mandatory fees in your DMS. Let HomeNet syndicate the final fee-inclusive price to every channel. Each tool doing its job. No gaps. No exposure.
Your 30-60-90 Day Action Plan
You do not need a lawyer to start this. You need a process. Here is what I tell every dealer I work with.
Days 1–30: Know Where You Stand
1
Pull Three Random Deals From Last Month Compare what was advertised online on the day of sale to what appeared on the buyer's order. If the numbers do not match — excluding only taxes, tags, and title — you have a gap that needs to close today.
2
List Every Fee You Charge Write them all down. Ask: does every single customer pay this? If yes, it is mandatory and must be in the advertised price. Run your full fee list through this filter with your office manager.
3
Map Your Syndication Chain Ask your inventory provider: where does our price originate? Where does it go? How long does a price change take to appear on AutoTrader? You need those answers.
Days 31–60: Close the Gaps
4
Configure Fee-Inclusive Pricing in Your DMS Work with your DMS rep to build mandatory fees into price calculations at the source — before prices leave your system and go anywhere.
5
Verify Your Syndication Provider Carries the Compliant Price Confirm the integration is pulling the fee-inclusive price field from your DMS. If you need help assessing your current setup, our consulting team can walk you through it.
6
Retrain Sales and F&I Advertised price = base + mandatory fees. Only taxes, registration, and title get added at the desk. Optional add-ons must be presented in writing as optional before the customer agrees.
Days 61–90: Lock It In
7
Run Monthly Spot Audits Five buyer's orders, random. Compare to what was listed when the lead came in. Document it. If you are ever investigated, that documentation is your first line of defense.
8
Explore FeeSync & Ongoing Updates S&P Global's FeeSync platform launched May 2026 as a free industry-wide fee management tool. Our management team is tracking the rollout and vendor adoption actively.
📞 Need a Compliance Assessment?
Carsignment offers dealer consulting services including inventory syndication audits, fee structure reviews, and HomeNet configuration support. I have been doing this for over 20 years and I will give you a straight answer — not a sales pitch. If your pricing is clean, I will tell you that too. Reach me directly at halsey@carsignment.com.
Frequently Asked Questions
Is the FTC CARS Rule still in effect in 2026?
No. The Fifth Circuit vacated the CARS Rule on January 27, 2025, on procedural grounds — it never spent a day as enforceable law. However, the FTC continues aggressive enforcement using Section 5 of the FTC Act, which has prohibited deceptive advertising since 1914.
What fees must be included in my advertised price?
All mandatory dealer-imposed fees — processing fees, freight, dealer-installed accessories charged to every customer. The only exclusions are government-mandated charges: sales tax, registration, and title. If every customer pays it, it belongs in the advertised price.
What is the actual financial risk for non-compliance?
Honda of Bowie: $3 million civil penalty plus consumer refunds spanning January 2019 through May 2022. Lindsay Automotive: $3.1 million civil penalty plus over $75 million in potential consumer refunds covering deals from 2020 through 2023. The multi-year refund window is the most dangerous part — it means liability extends back years, not just to when you were caught.
Does HomeNet automatically make my pricing compliant?
HomeNet distributes whatever price you feed it. Compliance starts upstream where you define the fee-inclusive price in your DMS or pricing system. HomeNet's compliance value is that once your price is correctly calculated, it syndicates that correct price consistently across every channel simultaneously — the consistency is what eliminates the gap the FTC targets.
Can vAuto replace HomeNet for compliance purposes?
No. vAuto is a market pricing intelligence tool. It does not syndicate inventory to third-party advertising platforms. FTC compliance requires fee-inclusive prices to appear consistently across every place consumers see your vehicles — that is a syndication function. That is HomeNet's domain.
My processing fee varies by deal type. How do I handle that?
Fees that vary may qualify as optional or conditional — but must be clearly disclosed before the customer agrees to pay them. Fees tied to financing sources must be disclosed in advertisements that reference those conditions. Work with a compliance-aware dealer attorney to classify your specific fees, then configure your pricing system accordingly.
Legal Disclaimer
This article is published for informational and educational purposes only and does not constitute legal advice. All information regarding enforcement actions and settlements is sourced exclusively from publicly available documents including official FTC press releases, court filings, and state attorney general announcements. Carsignment is not affiliated with any dealership referenced in this article. All references to enforcement actions reflect publicly reported government proceedings, presented factually and without editorial embellishment. Dealers with specific compliance questions should consult a licensed attorney with experience in FTC and consumer protection law. References to technology vendors including HomeNet Automotive and vAuto reflect publicly documented product capabilities and do not constitute a paid endorsement.
Recent Comments