All Dealerships Urged to Take FTC Warnings About Deceptive Pricing Seriously as Scrutiny Ramps Up

Brooke Conkle and Chris Capurso, attorneys with Troutman Pepper Locke and co-hosts of Moving the Metal: The Auto Finance Podcast, were quoted in the May 19, 2026, Automotive News article, “All Dealerships Urged to Take FTC Warnings About Deceptive Pricing Seriously as Scrutiny Ramps Up.”

• “I would characterize them as a warning shot,” said Brooke Conkle, a partner at Troutman Pepper Locke. “Even if you didn’t receive one, the FTC is telling everyone: This is the framework that we’re working under.”

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• “There was a perception that federal regulation might be on the back burner. These letters suggest otherwise,” said Chris Capurso, counsel at the Troutman Pepper Locke law firm.

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• “It’s not just print or digital ads,” Capurso said. “It can include social media … even what a salesperson says to bring a customer into the dealership.”

• “If there’s one area I would target, it would be [document] fees,” Conkle said. “Then look at add-ons; how are add-ons being advertised?”

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• “If a dealer is going to be sued, that usually is going to be where the rubber meets the road,” Conkle said. “If something is missing or unclear, it’s going to show up in those documents.”

• Customer complaints are another signal dealers shouldn’t ignore, Capurso and Conkle said.

• “If it’s easier for a consumer to get in touch with a regulator or a plaintiff’s lawyer than it is for them to get in touch with you, that’s a problem,” Conkle said.
• Even weak complaints can highlight confusion around pricing or fees, and point to larger process issues, she said.
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• “Now we have warning letters and guidelines … talking about what is [an Unfair or Deceptive Acts or Practices] in vehicle price advertising,” Capurso said. “And we could see states pursuing these types of actions, too.”
• For dealerships that didn’t receive a letter, the risk is ignoring its message, Conkle said.
• “The biggest mistake is twofold — not treating these letters seriously, and presuming that because we’ve had an administration change, it’s essentially the Wild West,” she said.