FTC Warning Letter to Automotive Dealers dated March 13, 2026

This statement is for general informational purposes only and reflects Spireon's business perspective; it does not constitute legal advice or a legal opinion. Dealers should consult with their legal counsel regarding advertising, pricing practices, and compliance obligations under applicable federal, state, and local laws.

The Federal Trade Commission ("FTC") sent letters to 97 auto dealership groups on March 13, 2026, emphasizing the need for advertised vehicle prices to reflect the total price consumers will be required to pay, with the sole exclusion being required government charges such as tax, title, and registration. According to the FTC, advertising a price that is lower than the price ultimately charged, due to mandatory fees or mandatory add-on products, may constitute a deceptive practice under Section 5 of the FTC Act.

This statement responds to requests from Spireon customers for information about the applicability of the FTC's letter to sales of LoJack devices.

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FTC Advertising Principles

In the letter, the FTC is repeating its position that an advertised sale price should accurately reflect the actual "out the door" price, excluding government required charges such as tax, title and license fees. The FTC clearly stated that all mandatory dealer-imposed charges must be included in the advertised vehicle price. Disclosures appearing in fine print or later in the transaction process generally will not be sufficient to correct a misleading headline price. This means that dealers must clearly identify what additional items and services are mandatory as part of the vehicle purchase.

Application to LoJack Devices

To be clear, the FTC has not required the price of LoJack to be included in the advertised vehicle price, as long as it is not mandatory for inclusion in the sale, and has not prohibited the sale of vehicles with installed LoJack devices or installing LoJack devices prior to sale.

Vehicle Pricing

Dealers should ensure that the advertised vehicle price include any mandatory add-on services or fees, other than tax, title and license. Adding a mandatory fee that was not included in the advertised vehicle price will create a compliance risk and is unlikely to be cured by fine-print disclosures.

Whether to include the price of LoJack in the advertised vehicle price

If purchase of LoJack is required, the advertised price of the vehicle should include the cost of LoJack. The vehicle description could include a reference to LoJack as being installed on the vehicle or included in the sale. The following explanatory language could be added to the advertising.

• "Advertised price includes installed LoJack theft recovery device. Advertised price excludes tax, title, registration, and other required government charges."

Where LoJack is offered as an option, the purchaser must have a meaningful ability to decline the product. In such case, the advertised vehicle price does not need to include the optional price of the LoJack device. Advertising could include the following options:

• "Protect your purchase with a LoJack theft recovery device, available separately."

• LoJack continues to provide meaningful value to dealerships and their customers. For consumers, it is a stolen-vehicle recovery platform with direct law-enforcement integration that goes beyond the location-notification features available in OEM connected-services packages. For dealerships, it also supports inventory visibility, marketing functionality, and lot-management workflows that are not addressed by OEM telematics.

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Reference
FTC Press Release: "FTC Warns 97 Auto Dealership Groups About Deceptive Pricing" (March 13, 2026) - ftc.gov

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