2026 Pub. 16 Issue 2

Julie Cardosi, Esq. Law Office of Julie A. Cardosi, P.C. The Federal Trade Commission’s (“FTC”) recent decision to issue warning letters to 97 dealership groups across the country in the 1st quarter 2026 marks a significant escalation in the agency’s scrutiny of automotive advertising practices. For Illinois dealers, the implications are especially important. Not only does Section 5 of the FTC Act1 prohibit unfair or deceptive acts or practices, but Illinois dealers must also comply with Section 2 of the Illinois Consumer Fraud and Deceptive Business Practices Act (“ICFA”)2, which imposes its own broad prohibitions on misleading advertising, along with the Illinois Motor Vehicle Advertising Regulations3 promulgated under the ICFA. Together, COUNSELOR’S CORNER A Heightened Federal and State Enforcement Environment Illinois Auto Dealers Must Strengthen Advertising Practices Now these laws create an integrated regulatory framework that demands careful attention to how vehicle prices, fees, add-on products, and terms are presented to consumers. The FTC’s letters focused on advertising practices that were alleged to create misleading impressions about vehicle prices, availability, financing terms, and add on products. In many cases, the agency identified advertisements that promoted prices consumers could not actually obtain because mandatory fees or dealer installed items were added later in the transaction. The FTC also criticized disclosures that were unclear, buried in fine print, or contradicted by more prominent statements. The FTC letters serve as a 14 ILLINOIS AUTOMOBILE DEALER NEWS

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