Warning to Auto Dealers: The FTC Is Watching Your Advertising Practices – and So Is Connecticut

On March 13, 2026, the Federal Trade Commission (FTC) announced that it is sending warning letters to 97 auto dealer groups nationwide notifying them – and the industry at large – that the advertised price of a vehicle must include all mandatory fees and be the total price that consumers will be required to pay, aside from required government charges (i.e. taxes and registration).  The letters provide the following examples of illegal pricing practices:

• Advertising a price that does not reflect all required fees.
• Advertising a price that reflects rebates or discounts not available to all consumers.
• Advertising a price that fails to account for the amount of an additional down payment required.
• Conditioning the advertised price on consumers using dealer financing.
• Requiring consumers to buy additional items not reflected in the advertised price.
• Advertising unavailable or nonexistent vehicles.

The letters do not state that any specific dealer has violated the law, but they make clear that the FTC is actively monitoring the marketplace and will take additional enforcement action as warranted.  There was a belief that the Trump-Vance FTC would be less focused on the automobile dealership industry than it was under former Chair Lina Kahn’s leadership, especially after the FTC’s proposed Combating Auto Retail Scams (CARS) rule was invalidated by a federal court in 2025.  However, the letters make it clear that the FTC is still actively monitoring dealerships and will seek to bring enforcement actions where warranted.  Further, the letter references three lawsuits involving the FTC against dealerships across the country for advertising practices and related claims, a sobering reminder that authorities are pursuing these violations aggressively.  Therefore, all automotive dealers should take this as an opportunity to review their advertising practices to ensure compliance with the FTC’s guidance, as well as state law.

What are Connecticut’s Advertising and Disclosure Requirements for Auto Dealers?

Last year, Connecticut adopted its own changes to advertising and disclosure requirements in the automobile dealership marketplace, which became effective on October 1, 2025.

• Under amended Connecticut General Statute Section 14-62a, a dealer may not advertise the price of any motor vehicle unless the stated price includes the federal tax, the cost of delivery, dealer preparation, any fee, charge, or cost imposed for any add-on consumer goods or consumer services, and any other charges of any nature.
• In addition to the longstanding requirement that the advertisement state, in at least eight-point bold type, that state or local taxes, registration fees, and the dealer conveyance or processing fee are excluded from the advertised price, the law now also requires that the advertisement separately state, in at least eight-point bold type and immediately next to the phrase "Additional Fees, Charges and Costs," the amount of any fee, charge, or cost imposed for any add-on consumer good or consumer service.
• The amendments also impose new requirements on prices quoted directly to prospective buyers. A dealer quoting a selling price must now include any fee, charge, or cost imposed for any optional add-on consumer good or consumer service and must separately state the amount of each such fee, charge, or cost and disclose that such fee, charge, or cost is negotiable.
• Finally, the form used by a dealer for the order and invoice may not be printed in advance of discussions with a prospective buyer to include the amount of any fee, charge, or cost for optional add-on consumer goods or services. This provision is designed to prevent dealers from presenting add-on costs as a fait accompli before any discussion has taken place.

In light of these overlapping federal and state developments, dealers, especially those operating in Connecticut, should conduct a comprehensive review of their advertising to ensure that every advertised price includes all mandatory fees and charges aside from government-imposed taxes. This includes online listings and social media.  Second, they should also evaluate whether any advertised discounts or rebates are truly available to all consumers and ensure that no price is conditioned on the consumer’s use of dealer financing or purchasing additional products.  Third, dealers should confirm compliance with Connecticut's new disclosure requirements by verifying that advertised and quoted prices state separately, in the required typeface and format, any fees for add-on consumer goods or services.  Finally, they should review order and invoice forms to ensure they are not pre-printed with optional add-on fees before any discussion with a prospective buyer.

The convergence of the FTC's warning letter campaign and Connecticut's new statutory requirements sends a clear warning to dealerships in this state.  Dealers who act now to bring their advertising, pricing and sales practices into compliance will not only avoid enforcement risk but will also position themselves as transparent, trustworthy competitors in an increasingly regulated marketplace.