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The FTC Cars Rule
Resource Center

The FTC finalized a new rule focused on advertising, pricing, add-ons, and customer consent when buying a car – known as the Combating Auto Retail Scams (CARS) Rule.

Here, you’ll find a variety of content to help you navigate the FTC CARS Rule, which goes into effect July 30, 2024.

Resources include:

  • A comprehensive Frequently Asked Questions + Answers detailing the new mandates
  • A brief, two-page Reference Sheet highlighting the new changes
  • Articles and webinar recordings for our series covering the CARS Rule in detail
  • White papers, blog posts, expert notices, and more (coming soon)
  • Information about our new ai-powered F&I, marketing, sales, and ad engine, Guardian, and how it provides you with solutions to the Rule (and a variety of federal and state F&I regulations)

Continue to check back, subscribe to our newsletter, and download useful information. Our experts will continue to provide updates, new content, and other resources.

We’re here to help!

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Stay up-to-date on the CARS Rule and a variety of other F&I, sales, and advertising rules and regulations

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FTC Cars Rule
Reference Guide

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The Dealer CANNOT

  • List vehicles that are unavailable for sale.
  • State untrue or misleading “pre-approval” claims.
  • Imply the ability or willingness to finance everyone.
  • Provide guaranteed trade-in allowance & trade payoff promises without a disclosure that negative equity will be added to the loan/lease balance.
  • Claim a product or dealership is endorsed or associated with the US government or military.
  • Have “View Details”, “Important Information”, or similar links that need to be clicked to see disclaimer language.
  • Make misleading statements about export or transportation rules.
  • “Speed read” disclosures in radio and television advertisements.

The Dealer CANNOT

  • Use “call for details”, “unlock price”, or similar in lieu of an “offering price” in a vehicle advertisement.
  • Provide “MSRP only” advertising that doesn’t include the actual asking price.
  • Sell above the MSRP unless the specific asking price is listed in the ad.
  • Exclude doc fees, mandatory add-ons, filing charges, or other non-governmental fees from the advertised price.
  • Include rebates that all customers wouldn’t qualify for, such as “high credit score” rebates, in the advertised price, unless clearly disclosed.
  • Respond to a consumer’s inquiry about a specific vehicle without including the “offering price.”
  • Advertise finance or purchase specials for a group of vehicles without showing the vehicle’s “offering price.”
  • Display the monthly payment in a formula such as “$XX.XX per month per $1,000 financed” in finance specials.

The Dealer CANNOT

  • Display a monthly payment without disclosing (1) the total amount the customer will pay after making all payments and (2) the total amount due at signing or downpayment.
  • Compare two monthly payments with varying amounts without a clear disclosure that the customer will pay more over the life of the loan for the lower payment.

The Dealer CANNOT

  • Exclude pre-loaded “mandatory” dealer add-ons from the advertised price.
  • Include or charge for “optional” add-ons without (1) a clear and conspicuous disclosure stating that the add-ons are optional and (2) not required for vehicle purchase/finance/lease.
  • Advertise add-ons that provide no benefit.
  • Sell GAP when there is no value to the customer (low LTV ratio) or GAP terms exclude the customer’s locality.

The Dealer MUST keep for 24 months

  • F&I training materials and sales scripts
  • Advertising and marketing materials
  • Backups and exports from social media services, email platforms, chat platforms, and texting systems
  • All written communications, including email, text, and CRM communications between customer and sales staff for consummated transactions
  • Finance & lease paperwork signed by the customer, whether or not the deal is consummated
  • LTV calculations, such as in GAP contracts or credit applications submitted to banks
  • Copies of all products and add-on paperwork and contracts
  • Copies of all consumer complaints, including those on social media
  • Copies of all inquiries related to vehicle and add-ons

The Dealer MUST use a disclosure form that includes the following:

  • Price of each add-on and any other dealer fees
  • Description of each charge
  • Initials next to each charge
  • Whether each add-on is optional or mandatory
  • Total cost with and without each add-on
  • Clear disclosure that optional add-ons do not need to be purchased
  • Clear disclosure that GAP is not necessary to obtain financing
  • Customer signature at the bottom

FTC Cars Rule
Articles

Part 4: Vehicle Advertising and a Brief Refresher of Reg M, Reg Z, the CARS Rule

Part 3: Rebates and the Offering Price in the First Communication

ComplyAuto Selected to Co-Author Vehicle Shopping Rule Manual and Featured to Speak at the NADA Conv…

Part 2: A Song of Inventory and Availability

INDUSTRY ALERT: FTC DELAYS CARS RULE EFFECTIVE DATE

The FTC Wastes No Time: CT Dealer Hit for Deception, Junk Fees, CPO, Add-Ons

Give me a Brake: A Summary of the CARS Rule

Part 1: The End of ‘MSRP-Only’ Advertising

FTC Cars Rule
Webinars

FTC Cars Rule
FAQs

Why Download?
The FTC CARS Rule is the most comprehensive set of federal regulations for the automotive dealership industry in history. In this comprehensive review of the Rule, our compliance experts provide detailed answers to some of the most common questions about the new mandates.

Download FAQs

ComplyAuto Guardian
Brochure

Why Download?
Downloading the PDF brochure about ComplyAuto Guardian is vital for dealerships seeking a revolutionary compliance solution. Designed by dealers for dealers, this innovative AI-powered engine offers comprehensive oversight, scanning ads for issues, and auditing deal jackets.

Download Brochure

Contact a ComplyAuto compliance expert for assistance

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About
ComplyAuto Guardian

We’ve known the FTC CARS Rule was coming and we’ve built an automated solution that is:

  • Scans your website for compliance violations
  • Checks and fixes ads for over 100 compliance issues
  • Catches issues before the vehicle is delivered
  • Automates compliance with other F&I rules, such as TILA, Reg M, Reg Z, and more.
  • Includes deal jacket audits, employee F&I training, and policy builders
Learn More

PREVENT

We want to enroll our employees in preventative training to prevent BAR citations and fines.

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ASSIST

We received a citation or disciplinary action and need to take remedial training.

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Mock OSHA Assessment

FEATURES:

  • On-demand eight-hour assessment that imitates a real OSHA audit.
  • Conducted by an EHS Pro with OSHA-10 or OSHA-30 certification and 5+ years of experience. 
  • Simulated employee interviews
  • Issue tracking and task management
  • Detailed assessment reports after the assessment with images, videos, and recommended steps for remediation.

    Privacy & Cyber Compliance Suite

    FEATURES:

    • Custom legal policies with real-time updates, including the Information Security Program (ISP)
    • Customized Incident Response Plan (IRP)
    • Internal risk assessment tools and hands-on guidance
    • Biannual penetration testing (2) 
    • Biannual vulnerability scans (2)
    • Employee security awareness training and completion tracking
    • Extensive vendor management library – hundreds of vendor-completed GLBA contracts & risk assessments
    • Device & systems inventory automation and mapping tools
    • Unlimited industry-specific internal phishing simulations to train staff
    • Complete 50-state privacy compliance required by your state (CA, CO, CT, DE, IA, IN, MT, OR, TN, TX, UT, VA)
    • Website cookie consent banners and unique consumer privacy request portals
    • Annual report to the Board of Directors generated every year
    • Compliance Guarantee

      CPR/AED Certification

      FEATURES:

      • Instruction provided by Certified American Red Cross Instructors.
      • Practical, hands-on training sessions to practice CPR and AED techniques
      • Proper automated external defibrillator (AEDs) instruction and operation
      • American Red Cross exam and certification
      • Access to study materials, manuals, and resources for continued education and reference.
      • Available for organizations and groups, allowing for tailored training sessions.

      HR Fundamentals

      FEATURES:

      • Customized policy builder with real-time updates
      • E-sign functionality for required employee policies 
      • Online HR training with employee completion tracking
      • State-specific policies and training
      • Employee management tool
      • Training and policies include Workplace Violence, Active Shooter, IT and Electronic Device Use, Biometric Data Privacy, Sexual Harassment, and more 
      • HR Fundamentals access is included with any other ComplyAuto product

        Encrypted Messaging

        FEATURES:

        • Encrypt SMS text and email messaging among staff, clients, and customers when sending and receiving files
        • Track usage and detect violations in real-time
        • Advanced security features include auto-deletion of files, Multi-Factor Authentication protection, IP safelisting, and domain blocklisting
        • Supports compliance with various state and federal regulations and recognized industry standards: GLBA, HIPAA, SOC 2, ISO 27001, NIST, CIS Controls, SEC

          Safety Compliance Suite

          FEATURES:

          • Concierge on-site onboarding 
          • On-demand safety walkthroughs conducted by experienced EHS Pros at various intervals – once, twice, or four times per year
          • Comprehensive Online Training Library and employee progress tracking
          • Automated 50-State Legal Injury & Illness Reporting
          • Policy Builders with Automatic Updates
          • Simplified SDS Creation and Management
          • Guided risk mitigation
          • Signage builder & tracking
          • Efficient equipment inspections with QR Codes
          • Tier 1 Spill Prevention Control and Countermeasure Plan 
          • Automated Tier 2 environmental reporting for all 50 states 
          • Unlimited one-on-one support from our dedicated team
          • Workplace Violence and Active Shooter Policy and Training
          • Unlimited one-on-one support from our dedicated team
          • Automated Tier II environmental reporting for all 50 states.

            EduTech Course 3

            Program to Fulfill AG Disciplinary Order - $299/student

            The California AG routinely penalizes facilities that violate these laws and requires them to perform specific remedies while on probation. One of these remedies requires the ARD to take a course that outlines the laws and regulations of the Automotive Repair Act. This program fulfills the requirement.

            FEATURES:  

            • Comprehensive online course about the Automotive Repair Act

            • Access to training materials anytime (24/7/365)

            • Comprehensive companion manual to the training material

            • Quizzes and final exam to track engagement and learning ability

            • Certificate generated upon completion

            EduTech Course 2

            Remedial Training and Attorney General Disciplinary Order - $299/student

            The Bureau of Automotive Repair (BAR) has allowed violating automotive repair dealers to take a remedial training program in lieu of having their information posted on a public website. Additionally, automotive repair dealers are required to take a training course as part of the California Attorney General’s disciplinary order. 

            This course fulfills both of these requirements.

            Created by California attorneys with over 35 years of combined experience in the automotive repair industry, this course is the only course on the market that is taught by instructors who are certified by the BAR.

            FEATURES:

            • Comprehensive online course about the Automotive Repair Act
            • Instruction by providers certified by the BAR
            • Access to training materials anytime (24/7/365)
            • Comprehensive manual that is a companion to the course
            • Quizzes and final exam to track student engagement and information retention
            • Certificate generated upon completion
            • Automated notification to the Bureau of Automotive Repair, if applicable

             

            EduTech Course 1

            Automotive Repair Act Certification Training - $49/month per rooftop

            With new regulations giving the Bureau of Automotive Repair (BAR) more authority to find violations and enforce citations upon repair facilities, it is now more important than ever to make sure your staff is knowledgeable about the Automotive Repair Act. Protect your repair facility from BAR scrutiny by enrolling into EduTech’s Automotive Repair Act Certification Training. This is the only training in California that is approved by BAR. 

            “Evidence of voluntary participation in retraining [of]…employees” as a mitigating factor. – Guidelines for Disciplinary Orders and Terms of Probation, BAR

            BAR has allowed retraining to be a “factor in mitigation” when investigating a repair facility. Therefore, as a preventative measure, it is strongly recommended that all technicians and service writers enroll into this course to show the BAR that you acknowledge and understand these rules before any investigation ever occurs. 

            All students enrolled in this product will be eligible for our “EduTech Guarantee” which financially protects repair facilities from enforcement by the Bureau of Automotive Repair. For more information, please visit our Terms of Service.

            FEATURES:

            • Online training course about the Automotive Repair Act
            • Only training course that is approved by BAR
            • Access to training materials anytime (24/7/365)
            • Quizzes and final exam to track student engagement and information retention
            • Certificate generated upon completion

            BENEFITS:

            • Lower risk of BAR scrutiny by standardizing correct practices
            • Increased customer satisfaction
            • Establishes good faith efforts and may avoid BAR citation and fine
            • Professional development for service writers and technicians
            • Eligibility for the EduTech Guarantee

            Students enrolled in this product will also have complimentary access to HR training materials and policy builders. Topics include:

            • Sexual harassment (supervisory and non-supervisory)
            • Active shooter
            • Workplace violence
            • Social media use
            • Biometric data (timekeeper or key lockbox)

            F&I Compliance Suite

              • Precise Deal Jacket Audits to identify and address real-world F&I compliance issues accurately.
              • Focused Compliance on specific F&I compliance concerns such as Fair Lending Compliance Solutions, California Litigation, Vehicle Safety Recalls, Used Vehicle History, FTC Buyers Guide & Federal Warranty Disclosures, 
              • Automated EZ Cash Reporting & Anti-Money Laundering with IRS Reporting 
              • Spot Delivery & Unwind Management
              • Real-Time Issue Identification Quickly detect compliance gaps and issues, enabling swift corrective action and risk mitigation.
              • Online F&I Compliance Training 
              • Compliance Guarantee

                Device & Email Security

                FEATURES:

                The combined features create a dynamic defense system that adapts to evolving cybersecurity threats and secures the organization's digital ecosystem.

                • Continuous threat detection and response powered by Coro:
                  • EDR (Endpoint Detection and Response) 
                  • MDR (Managed Detection and Response) 
                  • 24/7 Security Operations Center team
                  • Swift response and alert to potential security breaches
                • Enhanced authentication and access control via Multi-factor Authentication (MFA) powered by Duo Security™
                • Advanced email security to shield e-threats such as phishing, malware, spam, and scams – integrates with Google Workspace & Microsoft Office 365.
                • Data governance and Data Loss Prevention (DLP)  detect and manage employee data-sharing practices. 
                • Device-level encryption for Windows and macOS
                • Public & unencrypted wifi blocking
                • Next-gen antivirus
                • Automated password policy and session locking enforcement