The federal CARS Rule is gone. The dealership problems it was intended to address—including misleading advertised prices, disputed add-ons and inconsistent payment representations—did not disappear with it.
For a general manager, that distinction matters. A price can begin as an inventory listing, change in a marketplace feed, pick up conditions during a phone call and appear differently again on a worksheet. Even when nobody intends to mislead a customer, those handoffs can create complaints, abandoned appointments and evidence that attracts regulatory attention.
What changed in FTC dealer pricing oversight
On Jan. 27, 2025, the U.S. Court of Appeals for the Fifth Circuit vacated the FTC’s Combating Auto Retail Scams Rule, commonly known as the CARS Rule. The court concluded that the agency had not completed a required advance-notice step before starting the rulemaking process. The rule’s nationwide requirements, including provisions addressing offering-price disclosures and consent for add-on charges, therefore did not take effect.
That decision addressed the rulemaking process; it did not approve the pricing practices the FTC had targeted.
The FTC can still challenge conduct it considers unfair or deceptive under Section 5 of the FTC Act. Other statutes may apply depending on the facts, including the Truth in Lending Act and Equal Credit Opportunity Act, and available remedies depend on the legal authority and forum involved. State attorneys general and other state regulators also retain their own consumer-protection and dealer-advertising powers. A review of the FTC’s CARS Rule materials and the federal case record in August 2026 continues to reflect the rule’s vacated status, rather than a revival of its requirements.
The Leader Automotive order remains the useful warning
The action against Leader Automotive Group and parent company AutoCanada shows why the CARS Rule’s removal should not be confused with the removal of enforcement exposure. In December 2024, the FTC and Illinois attorney general alleged that dealerships advertised prices that did not reflect what many customers had to pay, charged for unwanted add-on products and engaged in discriminatory financing practices affecting Black and Latino customers.
The matter was initially announced as a proposed $20 million settlement because judicial approval was required. The current federal docket, reviewed Aug. 28, 2026, shows that the court entered the stipulated order and that it remains operative. It is therefore more accurate today to describe the matter as a final $20 million order, not merely a proposed settlement. The order includes monetary relief and restrictions governing future sales, advertising, add-on and financing practices.
The allegations relied on established consumer-protection and fair-lending authority rather than on the vacated CARS Rule alone. That makes the case especially relevant now. It also demonstrates how an advertising issue can expand when the same offer is interpreted differently by marketing, sales, the desk and F&I.
I’d argue that the most preventable risk sits in those departmental handoffs, not in any single document.
Build the review around the customer’s price journey
The following checklist is an operational starting point, not a compliance benchmark or legal advice. Sample size and review frequency should reflect inventory volume, advertising changes, complaint patterns, exception rates and state-law exposure. Counsel should define what must be included in advertised and out-the-door figures for each jurisdiction where the dealership operates.
- Advertised prices: Sample new, used and promoted vehicles to confirm that displayed figures are available on the stated terms. Place material conditions where customers are likely to see and understand them, and review the overall impression rather than relying on a disclaimer to cure a prominent claim.
- Fees and required charges: Assign one owner to maintain the dealership’s approved fee language. Compare that language across listings, written quotes, worksheets and final deal documents. Definitions and disclosure treatment should follow applicable state law and advice from counsel.
- Conditional discounts: Confirm eligibility rules, expiration dates and combination restrictions before promotions go live. Avoid presenting several discounts as one attainable price when an ordinary customer could not realistically qualify for all of them.
- Optional products: Check whether sales presentations, payment discussions and F&I documents consistently identify customer-selected products as optional. Repeated appearance of the same product in quoted payments deserves management review.
- Payment quotes: Sample calls, texts and written quotes for the assumptions that materially affect the payment, such as term, amount financed, credit qualifications and customer contribution. The customer should not discover a major condition only after arriving at the store.
- Third-party marketplaces: Compare sampled vehicles across the dealership website and outside listing services. Syndication magnifies errors quickly: one outdated price or missing condition can appear in several public locations and remain visible through screenshots even after correction.
- Final figures: Compare the last amount communicated before the visit with the final buyer’s order. Required dealer charges, government fees, taxes and optional products should be handled according to applicable law and the dealership’s counsel-approved definitions, with unexplained differences escalated.
Make one manager accountable for consistency
Good pricing controls do more than reduce enforcement exposure. They cut down on repricing disputes, protect appointment quality and give employees a shared answer when customers ask what they will pay. The most useful management signals are often recurring exceptions: the same rebate repeatedly misapplied, a required charge omitted from phone quotes or an optional product appearing in nearly every proposed payment.
The immediate next step is simple: assign one manager to conduct a cross-channel sample review and report repeated discrepancies to the general manager. The CARS Rule is no longer in force, but consistency across advertising, conversations and deal documents remains the sounder operating standard.