Background of the Case
Federal and state regulators recently brought an enforcement action against a Connecticut dealership and several of its employees that should serve as a cautionary tale for dealerships nationwide. The Federal Trade Commission (FTC) and the Connecticut Attorney General alleged a pattern of deceptive practices that included inflating prices with undisclosed add-ons, charging questionable certification or inspection fees, and misrepresenting government registration costs. The action did not stop at the dealership entity; it also targeted (just as other recent enforcement actions nationwide have done) individual principals, sales managers, a general manager, and a finance manager.
As of September 2025, two former sales managers agreed to settlements, while litigation continues against the dealership and several other individuals. The complaint describes situations where consumers were allegedly charged thousands of dollars in hidden fees. In one case, regulators alleged that an “inspection” fee in excess of $5,000 was added to a certified vehicle even though the necessary inspection had already been performed. In another, they alleged that more than $7,000 in add-ons was inserted into the amount financed after the purchase price had been negotiated. The government also alleged that consumers were misled about the nature and amount of state registration and government fees. None of the individuals or entities involved, including those that settled, admitted wrongdoing or liability.
The Reach of Personal Liability
What makes this case particularly striking is the degree to which individual managers were held personally responsible. One of the settlement orders permanently enjoins a former sales manager from misrepresenting any material aspect of a transaction, including the true price, financing terms, warranty or certification status, and whether charges are optional. These restrictions apply not just at the store where the conduct occurred, but to any role he might take in the retail automotive industry in the future.
The order also imposed a personal monetary judgment of nearly $5 million. Although payment of the monetary judgment is suspended, the judgment remains enforceable in the future if the individual fails to comply with the order or is found to have misrepresented his financial situation. Critically, the order specifies that the judgment is nondischargeable in bankruptcy, meaning that the debt would survive any attempt to wipe it out through a future bankruptcy filing.
Alongside financial liability, the order establishes sweeping personal compliance obligations. The individual must submit ongoing reports, provide copies of the order to relevant staff in any business he controls, and maintain detailed records—including pencils, four-squares, and other deal worksheets—for a full twenty years. Regulators also reserved the right to monitor compliance through interviews, depositions, document reviews, and even undercover contacts. This combination of injunctive relief, financial exposure, and long-term monitoring demonstrates the seriousness with which the FTC and Connecticut Attorney General are pursuing personal accountability.
In addition, the sweeping compliance obligations and permanent injunction make clear that the risk of enforcement goes far beyond paying a fine. The notion that penalties can be written off like a parking ticket as just a “cost of doing business” is no longer viable. An often-overlooked aspect of enforcement is the lasting impact of injunctive relief and compliance obligations, which in this case may follow the individuals involved for the remainder of their careers.
Ongoing Risks for Other Individuals
While two managers have entered into settlements, the case remains active against other individuals and the dealership itself. This means that other individuals who allegedly played a role in pricing vehicles, adding products, or approving fees may soon face similar orders with equally lasting consequences. The fact that the FTC and Connecticut Attorney General are pressing forward against principals, a general manager, and a finance manager underscores that accountability does not stop at ownership. Anyone involved in approving, structuring, or finalizing deals is at risk of being held personally liable.
Lessons for Dealers Nationwide
This settlement follows a 2024 enforcement action in which the FTC and the Illinois Attorney General pursued both a dealership entity and a former vice president in his individual capacity for similar alleged unfair and deceptive practices. The message is unmistakable: personal liability for dealership staff is increasingly on the table, and it comes amid a broader surge in state-level consumer protection enforcement. These recent cases also show that consumer protection enjoys bipartisan support, even as some federal regulatory efforts appear to ease. Dealers must take advertising and sales compliance seriously, and employees must take personal responsibility as well. Individuals cannot shield themselves behind the dealership entity, nor can they excuse unlawful conduct by claiming they were merely following orders. The stakes are simply too high.
Another important lesson is that regulators are following the entire paper trail, not just the final contract. The injunction’s requirement to preserve pencils, four-squares, and desking worksheets for twenty years shows that regulators view the negotiation process itself as part of the compliance equation. At a minimum, dealers should ensure that advertised prices must match actual selling prices, add-on products and services must be clearly disclosed as optional and expressly authorized, and dealer fees and charges cannot be misrepresented as government requirements. Dealerships cannot rely on a clean final contract if the steps leading to it are tainted by misleading or unfair practices.
Protecting Both the Store and the Individual
The Connecticut case makes clear that personal liability is not limited to dealership owners or executives. Dealership employees, including sales managers, desk managers, general managers, and finance personnel, can all face direct exposure. The only way to protect both the enterprise and its employees is to implement compliance processes that align advertising, desking, and financing practices with federal and state requirements and that document consumer disclosures and authorizations at every step.
ComplyAuto helps dealerships achieve this by providing advertising compliance solutions, deal jacket review services, and our newest product, DealCheck Ai, which reviews deals before the customer leaves the dealership—all of which help dealers embed regulatory requirements into their everyday operations. By ensuring that disclosures are standardized, customer consent is clearly documented, and deal records are complete from the first pencil to funding, dealers can avoid the kinds of practices that have led to personal liability in Connecticut. With regulators increasingly willing to hold individuals accountable, these safeguards are becoming an essential part of modern dealership operations.