I am going to say what a lot of dealer principals are thinking but not saying publicly right now.

The FTC is not playing around this time. This is not the same regulatory noise we have heard every few years that eventually fades into a consent decree nobody reads. The scrutiny on dealership advertising practices right now is at a level I have not seen in twenty years in this business and I am genuinely concerned that a lot of operators are going to find out the hard way that their current ad stack is not compliant.

I had my attorney do a full review of our advertising last quarter. Digital, broadcast, print, in store signage, everything. The list of things that needed to change was uncomfortable to look at. And I say that as someone who thought we were running a clean operation. The gap between what we thought was acceptable and what is actually going to hold up to scrutiny right now is significant.

The specific things that keep coming up are addendum pricing in ads, not disclosing mandatory fees clearly enough, and the way financing offers are presented in digital campaigns. The days of burying the real payment in fine print while the headline number does all the work are over. The FTC has made it very clear they understand exactly how that game is played and they are done pretending they do not.

What worries me more than the big groups who have legal teams watching this around the clock is the mid size independent operator who is still running the same ad templates they have been using for ten years. Those are the stores that are going to get made into an example.
The Combating Auto Retail Scams rule may have had a complicated rollout but do not let the regulatory back and forth fool you into thinking the underlying enforcement pressure went away. It did not. The appetite to make visible examples out of dealerships is very much still there.
Get your advertising audited. Not by your ad agency. By an attorney who understands FTC compliance specifically. Your agency's job is to sell cars. Their job is not to protect you from a six figure civil penalty.

I am not trying to be alarmist but I am also not going to sit here and pretend this is business as usual. It is not.