FTC Greenway Order: What It Requires and a Dealer Compliance Checklist

On October 8, 2026, the FTC filed a complaint and a stipulated settlement against Greenway Auto Group, a set of Kia and Hyundai stores around Orlando. The FTC Greenway order is the first court order to come out of this year's dealer pricing push, and it reads like a compliance spec: a fee definition, a prominence standard, a safe harbor for third-party listings, bans on specific sales tactics, and five years of recordkeeping. Greenway is a franchise group, but every provision maps to something an independent lot does every week.

Watch: FTC Total Price Rule: Dealer Checklist

This post walks through what the FTC alleged, what each part of the order requires, and a dealer checklist mapped to those provisions. If you want the general fee math and VDP layout walkthrough, our FTC price transparency FAQs post is the place for that, and this post links back to it instead of repeating it. It is practical guidance from a dealer-website team, not legal advice. Run anything state-specific past your attorney.

What the FTC alleged against Greenway

The complaint, filed in the Middle District of Florida (Case 6:26-cv-02337), describes a pricing pattern many shoppers will recognize. Greenway advertised specific vehicles online and on third-party sites at one price, then charged more when the buyer sat down to sign. According to the FTC, buyers in more than 92% of transactions paid more than the advertised price, and those buyers paid an average of $3,354 more.

The complaint lists where the extra money came from:

Dealer-imposed fees. One Greenway Kia North disclaimer named a $1,199.95 Dealer Fee, a $399.50 Administration Fee, and a $189.95 PTA Fee, bundled in the same sentence as taxes, tags, and title.
Reconditioning or "inspection" fees that, according to the complaint, often appeared nowhere in the online listing.
A roughly $995 "loyalty" discount baked into the internet price, which only repeat customers could get.
Discounts that only applied if the buyer financed through the dealership.
Mandatory add-on packages, including a $2,295 "Greenway Advantage" package the complaint says staff told buyers could not be removed.
Government charges such as title and registration that the FTC says were inflated.

The fee disclaimer sat at the bottom of the VDP, below several screens of unrelated content. The FTC's complaint calls that fine print deceptive in its own right, because it mixed dealer profit items with government charges and made the add-ons look like taxes.

In March 2026 the FTC's Bureau of Consumer Protection sent warning letters to 97 dealer groups, Greenway among them, telling them the price in an ad has to be the price the buyer pays apart from government charges. According to the complaint, Greenway responded by adding banners that read "GREENWAY ALL-IN PRICE" and "ZERO HIDDEN FEES," plus new disclaimer copy promising transparent pricing. The complaint says that on May 28, 2026, a 2026 Kia Sportage X-Line advertised at a "Greenway Sale Price" of $37,752 was quoted in writing at $39,854.40.

The complaint also covers prize mailers that told recipients they had won cash they could collect at the dealership. The FTC says the prizes were not real.

What the FTC Greenway order requires, provision by provision

Greenway neither admitted nor denied the allegations. Per the FTC, a stipulated order has the force of law once the district judge signs it, and this one is specific enough to use as a checklist.

Total Price, defined

The order defines Total Price as "the maximum total price, including all mandatory fees or charges a consumer must pay for a motor vehicle," minus only charges that a federal, state, or local government requires the consumer to pay. Doc fees, dealer fees, admin fees, prep fees, reconditioning fees, and any package the buyer cannot decline all belong inside that number. Sales tax, title, and registration that go to the state can stay out. That matches the "actual price" standard FTC staff described in September, so if you already did the fee math from our pricing transparency FAQs walkthrough, the order confirms it rather than changing it.

Most prominent, clear, and conspicuous

Section II bars Greenway from showing "any amount a consumer may pay to purchase, finance, or lease" a vehicle without also showing the Total Price, clearly and conspicuously, "as the most prominently displayed item in any visual disclosure." That covers monthly payments, down payments, and "as low as" figures as well as the sticker number.

The order also spells out what clear and conspicuous means. A visual disclosure has to stand out by size, contrast, location, and how long it appears. On a website or app it has to be "unavoidable," so a link to a disclaimer page or a tooltip does not count. It cannot be contradicted by anything else in the ad, and in video it has to be spoken and shown at the same time.

A safe harbor for third-party listings

Greenway is not automatically in violation when a marketplace or other third party advertises one of its cars with the wrong number, as long as three things are true. Greenway gave the third party the Total Price and asked that it be shown as the most prominent item, Greenway did nothing to undercut that request, and Greenway took every step within its control to get the third party to display it that way.

Every dealer who lists on CarGurus, Cars.com, AutoTrader, Facebook, or Google vehicle ads faces the same question. Responsibility for the price on those sites starts with the feed and the request you send, and the dealer has to be able to show both.

Records by VIN and by channel

For five years, Greenway has to keep, for each advertised vehicle, the VIN or stock number, the vehicle description, the advertised prices and the dates those prices ran, and the disclaimer text it supplied. It also has to keep one representative ad per marketing channel per month, plus every pencil, four-square, buyer's order, and consumer complaint. That is close to a ready-made logging spec for any lot.

No fine, for now

The order carries no monetary relief. According to Hudson Cook's enforcement alert, after the Supreme Court's 2021 decision in AMG Capital Management v. FTC, Section 13(b) of the FTC Act does not let the agency collect money, and with the CARS Rule vacated there was no trade regulation rule violation to support civil penalties. Greenway still ends up under a federal injunction, with sworn compliance reports for years and court contempt as the risk if it slips.

Why an order against one group matters to an independent lot

The order binds only Greenway. Its Total Price definition lines up with what FTC staff told every dealer in writing a month earlier. The FTC's press release calls price transparency "a top priority," and it follows the September 15, 2026 staff FAQs we covered in FTC Price Transparency FAQs for Dealers. The FAQs were guidance. Greenway is a lawsuit against a group that got one of the March warning letters and, according to the FTC, kept advertising the same way.

Microsoft Advertising is moving the same way. Microsoft Advertising updated its pricing policy for U.S. automotive dealer ads in early October, with PPC News Feed spotting the change on October 2 and Search Engine Land reporting it on October 5. Coverage so far says the policy targets how vehicle prices and discounts are represented. If you run Microsoft search ads, pull the current policy text from your account before you change templates rather than relying on summaries.

Fee surprises also cost sales. Shoppers compare your listing to three others on the same screen. If your $14,995 car becomes $16,300 at the desk, the shopper who drove 40 minutes leaves a review about it, and that review sits on your Google profile longer than any price drop. Greenway's complaint describes a couple who confronted the dealership and then posted a negative review, after which the store lowered the online price on that same car.

Run Section II as a pass or fail test

Dealer laptop open to a vehicle page while a manager checks it against the FTC Greenway order requirements

Section II is the heart of the order, and it works best as a yes or no test rather than a redesign project. Open three of your vehicle pages and one marketplace listing on a phone and answer four questions. Is any payment, down payment, "as low as," or strike-through figure larger or higher on the screen than the all-in price? Is any required dealer fee missing from that price? Does any discount in the headline number depend on financing, a trade, loyalty, or a group affiliation? Is the fee explanation behind a link, tooltip, or footer instead of next to the price?

Any yes is a fail under the order's language. The fixes themselves (fee math per unit, price hierarchy, payment-widget labels, sold and in-transit status) are covered step by step in our lot-site audit for the FTC pricing FAQs, so work from that list and use this test to confirm the result.

Use Greenway's disclaimer as the example of what to delete

Windshield price card on a used car, a reminder that the FTC Greenway order counts dealer fees as part of the price

Greenway's original disclaimer named dealer fees in the same sentence as taxes and tags, ran about 240 words, and sat at the bottom of the page. The complaint treats that structure as deceptive on its own, because it made profit items look like government charges. A version that fits the order is two sentences, placed right under the price:

"Price includes all dealer fees. Sales tax, title, and registration fees paid to the state are extra."

If you sell optional products such as service contracts, GAP, or appearance packages, say they are optional and are not in the price, and make sure the desk treats them that way. Greenway also added "optional" language to its disclaimer, and the complaint says staff still told buyers the package could not come off.

Build a safe-harbor file for every third-party channel

The safe harbor protects Greenway only if it can prove three things: it supplied the right price, it asked for that price to lead, and it did everything in its control to get the listing fixed. For an independent lot on CarGurus, Cars.com, AutoTrader, or Facebook, that proof lives in a saved folder of emails and screenshots.

Send each marketplace rep a short written request that your listed price displays as your all-in price with dealer fees included, and save the email and the reply.
Keep one screenshot per channel per month next to the matching page on your own site, so you can show the numbers agreed on that date.
When a listing shows a different number, log the date you noticed, the follow-up you sent, and the date it was fixed.
Do the same for any agency or co-op program that runs ads in your name.

The safe harbor does not cover a feed you mapped wrong. If your Facebook catalog or Google feed pulls a pre-fee field, that is your error, and our post on Google vehicle ads feed and VDP mismatches covers how those drift. The order also bars misrepresenting "the availability of vehicles at an advertised price," so a sold unit still live on three marketplaces is a gap in the file too.

Only claim "no hidden fees" if the desk can back it up

After the warning letter, the Greenway stores added "ZERO HIDDEN FEES" and "the price you see advertised online is the real price" to their websites without changing what the sales desk quoted. In the FTC's complaint, those banners show up as proof that the dealership knew the rules.

Before you add a transparency badge to your site, run a quick test. Pick three stock numbers at random. Have someone who does not work the desk ask for a written out-the-door quote by text or email. Compare each quote, line by line, to the VDP price plus state tax, title, and registration. If any line other than government charges shows up, fix the process first and add the badge later. Our free out-the-door price calculator is a quick way to show a shopper the government charges on top of your Total Price.

Train the desk on the same point. A salesperson who says "that internet price was for financed buyers" is repeating one of the specific practices in the complaint. So is "every car gets our protection package." If a product is mandatory, it goes in the price. If it is optional, the buyer can say no and pay the advertised number.

Copy the order's five-year recordkeeping spec

Dealer desk with a binder of listing screenshots and a pricing spreadsheet kept the way the FTC Greenway order describes

The order's recordkeeping section is useful even for a 30-car lot, because it describes what an investigator or an attorney general's office would ask for first. A shared spreadsheet covers most of it.

One row per stock number with VIN, year, make, model, and the date it went live.
Each advertised price and the date it changed, including price drops.
The disclaimer text that ran with the listing.
A monthly screenshot of one listing from each channel you use (your site, CarGurus, Cars.com, AutoTrader, Facebook, Google).
Copies of the buyer's order and any worksheet used to pencil the deal.
Every price complaint, including bad reviews about fees, and what you did about it.

If your website keeps a price history per vehicle, export it monthly instead of retyping it. The goal is to show, for any car on any date, what price you advertised and what the buyer paid.

Prize mailers, loyalty pricing, and financing-only deals

Three smaller items in the order affect promotions independent lots run all the time.

Prize and scratch-off mailers are covered directly. The order bans misrepresenting whether someone won, what the prize is, and what it is worth. If you use a direct-mail vendor for a "you may have already won" piece, read the copy yourself. The dealership's name is on it, not the vendor's.

Loyalty or returning-customer discounts are fine as a separate offer. Greenway's problem, according to the complaint, was a $995 loyalty discount built into the advertised price that most buyers could not get. Keep the advertised number at what any buyer pays, and list the loyalty savings below it.

Financing-only pricing is the third. The order bars misrepresenting "whether any type of or source for financing is required" to get a vehicle at a particular price. Buy-here-pay-here and in-house finance lots should be especially careful. If cash buyers and outside-financing buyers pay a different price than in-house buyers, the advertised price has to be the one every buyer can get.

FTC Greenway order checklist for dealers

Each line below maps to a specific part of the order. Print it, work through it with whoever sets prices and whoever runs the desk, and date it when it is done.

Fee definition. You have a written list of every fee charged on every deal, each marked required or optional, and every required fee sits inside the advertised price.
Prominence (Section II). Three vehicle pages, one search results page, and one marketplace listing pass the four-question test above on a phone.
Clear and conspicuous. Nothing about fees lives only behind a link, tooltip, or footer, and any video ad that states a payment also says and shows the all-in price.
Conditional offers. Financing-only, trade-in, loyalty, and group discounts appear below the headline price with their conditions, never inside it.
Financing representations. Cash buyers and outside-financing buyers can buy at the advertised price, and nobody on the floor says otherwise.
Add-ons. Every package a buyer cannot decline is in the price, and every optional one can actually be removed at the desk.
Transparency claims. Any "no hidden fees" or "all-in price" badge has passed a three-car written quote test run by someone outside sales.
Safe harbor. Each third-party channel has a saved written price request and a current monthly screenshot.
Prize promotions. Someone at the dealership has read the copy on every mailer or scratch-off before it ships.
Records. A spreadsheet exists with VIN or stock number, advertised prices and dates, disclaimer text, monthly channel screenshots, deal worksheets, and price complaints, with a calendar reminder to keep it current.

Moving required fees into every listed price can push your cars lower on price-sorted marketplace results for a while. The trade is a listing that matches the desk, fewer walkouts, fewer one-star fee reviews, and a file that answers the first question an investigator asks.

Where AutoFire fits

AutoFire gives each car its own vehicle page on a lot website you run yourself. On Pro, the same inventory record feeds the private outbound feeds you share with marketplace partners, so a price you correct once on the website goes out to every enabled channel without a separate spreadsheet. That shortens the prominence and safe-harbor items on the checklist above. You can see how the feeds work on our inventory syndication page, or start a site at goautofire.com and keep one price on every channel.