FTC Buyers Guide Rules: Avoid $53,088-Per-Car Fines on Your Lot

If you sell used cars, federal law requires a Buyers Guide window sticker on every used vehicle you offer for sale — and getting it wrong is expensive. Dealers who violate the FTC's Used Car Rule can face penalties of up to $53,088 per violation. This guide is for used-car managers, GMs, and the lot attendants who actually place the stickers: it covers which vehicles need a Guide, where to post it so it counts as "conspicuous," which version to use, and how to keep your lot audit-ready between deals.

What the FTC Used Car Rule actually requires

The Used Car Rule has been on the books a long time. Formally known as the Used Motor Vehicle Trade Regulation Rule, it has been in effect since 1985 and requires car dealers to display a window sticker, known as a Buyers Guide, on the used cars they offer for sale. The Buyers Guide discloses whether the dealer offers a warranty and, if so, its terms and conditions, including the duration of the coverage, the percentage of total repair costs the dealer will pay, and which vehicle systems the warranty covers.

The penalty is per vehicle, not per lot. Dealers who violate the Used Car Rule may be subject to penalties of up to $53,088 per violation in FTC enforcement actions. And enforcement isn't only federal — many states have laws or regulations similar to the Used Car Rule, and some incorporate it by reference, so state and local law enforcement officials may have the authority to ensure that dealers post Buyers Guides and to fine them or sue them if they do not comply.

Which vehicles need a Guide — and when

The timing trips up a lot of stores. A car doesn't have to be lot-ready or detailed to need a Guide. Dealers must post a Buyers Guide before displaying a vehicle for sale or letting a customer inspect it for the purpose of buying it, even if the car is not fully prepared for delivery. That means the sticker goes on before the vehicle ever hits the front line.

Consignment and auction inventory count too. Dealers must display a Buyers Guide on used vehicles for sale on the lot through consignment, power of attorney, or other agreement, and at public auctions, dealers and the auction company must comply.

Where to post it so it counts

"Displayed" has a specific legal meaning. The Buyers Guide must be displayed prominently and conspicuously on or in a vehicle when a car is available for sale — meaning it must be in plain view and both sides must be visible. Acceptable spots include:

• Hanging from the rear-view mirror inside the car or on a side-view mirror outside the car
• Under a windshield wiper
• Attached to a side window

What does not count: a Guide in a glove compartment, trunk, or under the seat is not conspicuous because it is not in plain sight. And don't forget the test-drive rule — you may remove the Guide for a test drive, but you must replace it as soon as the test drive is over.

Fill out the header before it goes up. At the top of the Guide, fill in the vehicle make, model, model year, and vehicle identification number (VIN); you can write in a dealer stock number if you wish.

Use the current version, not last decade's

There are two variants depending on how you sell. One says "As Is – No Dealer Warranty" and the other says "Implied Warranties Only," and which one you can use depends on your state's rules on as-is sales. If you're selling a deal in Spanish, note that if a sale is conducted in Spanish, you must use the Spanish language Buyers Guide.

Also remember: the disclosures aren't just decoration. Information on the window form overrides any contrary provisions in the contract of sale.

Why this fails in real audits

Compliance sweeps show this is a widespread, ongoing gap. In the FTC's first sweep after the rule was amended, inspectors found Buyers Guides on 70 percent of the more than 2,300 vehicles inspected, with almost half of those displaying the revised Buyers Guide. In practice, the two most common failures are Guides that fall off or get pulled for a test drive and never replaced, and cars moved to the front line before a Guide is filled out and posted.

A simple lot-attendant checklist

• Post a Guide the moment a used unit lands — before it's detailed or fronted.
• Fill in make, model, year, and VIN on every Guide.
• Keep both sides visible; mirror-hang, side-window, or under-wiper only.
• Re-post immediately after every test drive.
• Spot-check consignment and auction units — they're covered too.

A big part of keeping Guides posted is using a holder that survives weather, car washes, and test drives instead of a loose sheet under a wiper. We stock current-version Buyers Guide forms and holders — including fold-over pouches, static-cling holders, and clip-on holders — and the full Buyers Guides & Holders collection if you want to standardize your whole lot.

This post is general information, not legal advice — confirm your state's specific as-is and Buyers Guide requirements with your compliance officer or counsel.