Dealership Commercials / What Disclaimers Does a Car Dealer Commercial Need?
What Disclaimers Does a Car Dealer Commercial Need?
A car dealer commercial needs added disclosures the moment it states certain credit or lease terms. Under the federal Truth in Lending rules, stating a monthly payment or a down payment in a financing ad requires the ad to also state the down payment, the repayment terms and the annual percentage rate. Lease ads have their own list under Regulation M.
Financing ads: Regulation Z
These terms in an ad are "triggering terms" under 12 CFR 1026.24(d):
- The amount or percentage of any down payment.
- The number of payments or the period of repayment.
- The amount of any payment.
- The amount of any finance charge.
If any one appears, the ad must also disclose the down payment, the terms of repayment, and the rate as an annual percentage rate, including whether that rate can increase after the sale.
Lease ads: Regulation M
Under 12 CFR 1013.7, a lease ad that states the amount of any payment, the number of payments, or an amount due at signing (including that nothing is due) must also state:
- That the transaction is a lease.
- The total amount due at lease signing or delivery.
- The number, amounts and due dates or periods of the scheduled payments.
- Whether a security deposit is required.
- That an extra charge may apply at the end of the lease when the lessee's liability depends on the vehicle's value at that time.
TV and radio
Both regulations include an alternative for broadcast ads, so a spot can point viewers to a toll free number or a written ad for some of the required details. Read the exact conditions in the regulation before relying on it.
What else a dealer spot has to get right
- Match the offer sheet. The payment, term, due at signing and end date on screen must match the deal the store is actually offering.
- State and manufacturer rules. State advertising law and the brand's co-op guidelines can add requirements.
- Expiration. Pull the spot when the offer ends.
This page explains the federal rules in plain language. It is not legal advice. Have your compliance contact review every ad before it runs.
Questions people ask
What is a triggering term in a car ad?
A specific credit or lease term, such as a monthly payment or down payment, that requires the ad to add further disclosures under Regulation Z or Regulation M.
Does a lease ad need different disclosures than a finance ad?
Yes. Lease ads follow Regulation M, which requires stating that it is a lease, the total due at signing, the payment schedule, the security deposit, and possible end of lease charges.