FTC Pricing FAQs: What RV Dealers Need to Know About Advertising

The Federal Trade Commission’s latest pricing-transparency guidance is giving vehicle dealers another reason to take a close look at how they advertise inventory online.

In September 2026, the FTC published a new set of frequently asked questions addressing how vehicle prices should be presented in advertising. The guidance covers advertised prices, mandatory fees, discounts and rebates, optional products, vehicles in transit, representative photos and the responsibilities of dealers, manufacturers and third-party advertising companies.

Although the FTC’s FAQ document is written for the automobile industry, the issues it raises are highly relevant for RV dealerships and the companies that manage RV dealer websites and advertising. RV News reported that the guidance is already prompting discussions about dealership compliance and pricing practices.

For RV dealers, the biggest takeaway is simple: the price consumers see in advertising needs to accurately represent the price they can actually pay, subject to the specific legal requirements and circumstances involved.

Important: This article is an industry overview, not legal advice. RV dealers should have their counsel review their specific pricing and advertising practices, including applicable state requirements.

Why the FTC Is Focusing on Pricing Transparency

The FTC says its concern is straightforward: consumers may see one price online and discover additional mandatory charges only after they contact or visit the dealership.

That makes it difficult for shoppers to compare vehicles accurately.

The agency says advertised prices should reflect the actual price a consumer can pay, with government-required charges treated differently under the FTC’s guidance. The agency’s stated objective is to prevent consumers from being attracted by artificially low advertised prices that increase later in the buying process.

RV News reported that industry representatives told the FTC there are operational complications surrounding pricing, inventory and third-party systems, which contributed to the development of the FAQs.

For RV dealers, this is particularly important because a single advertised price can appear across multiple places:

• Dealer websites
• Inventory detail pages
• Search results
• Google Ads
• Social media
• Third-party marketplaces
• Email promotions
• OEM websites
• Digital retailing tools
• Lead-generation platforms

A pricing discrepancy in one location can therefore create problems well beyond a single advertisement.

The Advertised Price Matters

One of the FTC’s central points is that if a dealer requires a consumer to pay a fee to purchase a vehicle, that mandatory fee generally needs to be included in the advertised price under the guidance. Government-required charges paid directly by the consumer are treated differently.

For example, if an advertised vehicle price is:

$39,999

but every consumer is required to pay another $1,000 dealer fee, simply advertising $39,999 may not accurately represent the actual price under the FTC’s guidance.

The practical question for dealers is:

“What does a consumer actually have to pay to purchase this vehicle?”

That answer needs to be reflected appropriately in the advertised price.

RV Dealer Websites Deserve Special Attention

The FTC specifically addresses online inventory pages.

When a webpage states an amount a consumer may pay, the actual price should be the most prominent price on that page. This includes inventory-search pages and individual vehicle listing pages.

This has important implications for RV dealer websites.

For example, a VDP could potentially display:

MSRP: $72,500
Dealer Price: $69,999
YOUR PRICE: $64,999

The important issue isn’t simply font size.

The FTC says prominence is determined by the overall presentation of the advertisement, not just whether one number happens to use a larger font.

For RV dealerships, marketing and website teams should therefore review how prices are displayed on:

• SRPs
• VDPs
• New RV inventory pages
• Used RV inventory pages
• Promotional landing pages
• Mobile versions of websites
• Lead-generation forms
• Digital retailing pages

Discounts and Rebates Need Careful Handling

The FTC does not prohibit dealers from advertising discounts or rebates.

However, the actual price must remain clear and prominent, and the conditions associated with a discount need to be understandable.

For example, a dealer may advertise a discount available to first responders or a financing-related incentive, but the advertised price that any consumer can obtain needs to be presented appropriately and the conditions must be clear.

This is particularly important for RV promotions that combine several incentives.

Examples might include:

• Cash discounts
• Manufacturer rebates
• Dealer discounts
• Trade-in incentives
• Financing incentives
• Military discounts
• First-responder discounts
• Loyalty programs
• Seasonal promotions

Dealers should make sure shoppers can distinguish between the actual broadly available price and conditional incentives.

What About Dealer Fees?

Mandatory dealer fees are another area that deserves attention.

The FTC says mandatory fees required by the dealer generally need to be included in the advertised price. Its example involving a $40,000 vehicle and an $85 mandatory document fee illustrates the principle: the advertised price would need to reflect the $40,085 amount rather than leaving the mandatory fee to appear later.

State laws can impose additional requirements, so dealers should not assume that following the federal guidance alone resolves every pricing-disclosure issue.

For RV dealers operating across multiple states, this becomes even more important.

A pricing structure that works in one state may require additional disclosures or treatment in another.

Optional Products Are Different

The FTC also distinguishes between mandatory charges and optional products or services.

Dealers can offer products such as accessories, protection products or other additional services, but advertising cannot mislead consumers into believing an optional product is required.

The FTC specifically warns against practices such as suggesting an optional add-on is mandatory or charging for an option the consumer did not agree to.

For RV dealers, this could be relevant to the presentation of products and services such as:

• Protection packages
• Extended service contracts
• Accessories
• Coatings
• Maintenance products
• Aftermarket equipment
• Other F&I products

The key distinction is between offering an option and representing an option as part of the required purchase price.

Vehicles in Transit Can Still Be Advertised

One of the more interesting parts of the new guidance concerns vehicles that aren’t physically sitting on the dealer’s lot.

The FTC says it is not inherently deceptive to advertise a vehicle that is in transit or located elsewhere.

However, the advertisement should clearly communicate that the vehicle isn’t physically on the lot. The vehicle must also actually be in transit and available for purchase after arrival rather than already allocated to another customer’s paid-for order.

This issue was particularly important to dealer representatives during discussions with the FTC.

RV News reported that the industry had concerns about earlier interpretations regarding how soon an in-transit vehicle could be advertised. The new FAQs removed a previously discussed specific time limitation, according to comments from NADA representatives cited by RV News.

For RV dealerships, this could be especially relevant because new RV inventory can be advertised before it physically arrives at a dealership.

The important part is transparency about availability and location.

Representative Photos Also Matter

The FTC says dealers may use representative photos when the image is genuinely representative of the vehicle being advertised and consumers understand that it is an illustrative image rather than necessarily the exact unit.

This is particularly relevant to RV websites.

RV dealers frequently use:

• Manufacturer photography
• Stock photography
• Model-level images
• Interior floorplan images
• 360-degree images
• Actual inventory photography

Dealers should make sure that the imagery and accompanying information don’t create a misleading impression about the exact unit being sold.

For used RVs, this becomes particularly important because two apparently similar units can have very different conditions.

Third-Party Marketing Companies Are Part of the Equation

Perhaps one of the most important points for digital marketers is that the FTC isn’t looking only at the dealership.

The FAQs say that dealers, third-party advertisers and OEMs can have responsibility when they control advertising content.

That’s significant for the RV industry because a typical dealer’s advertising ecosystem can involve several companies:

RV Dealer → Advertising Agency → Website Provider → Inventory Feed → OEM → Google/Meta → Third-Party Marketplace

Pricing data can move through multiple systems before it reaches the consumer.

That means a dealer shouldn’t assume:

“Our website company is responsible for the price.”

At the same time, agencies and technology providers should not assume:

“The dealer gave us the feed, so we’re automatically protected.”

The FTC guidance specifically discusses shared responsibility when multiple parties control advertising.

What RV Dealers Should Review Now

RV dealerships can use the new guidance as an opportunity to conduct a practical advertising audit.

1. Review VDP pricing

Check whether the advertised price accurately reflects the price a consumer can obtain.

2. Review SRP pricing

Don’t focus only on the individual vehicle page. Search-result pages also matter.

3. Check mandatory fees

Identify every dealer-required charge and determine how it is reflected in advertising.

4. Review promotions

Look carefully at rebates, discounts and financing incentives.

5. Audit inventory feeds

Make sure the price in the inventory management system matches what appears on the website and advertising platforms.

6. Review in-transit RVs

Clearly identify inventory that isn’t physically on the dealership’s lot.

7. Check sold inventory

Make sure sold units aren’t continuing to appear as available simply to generate leads.

8. Review representative photography

Make sure consumers can understand when a photograph is representative rather than an image of the exact RV.

9. Audit third-party advertising

Check Google, Meta, marketplaces, email campaigns and other channels where prices are displayed.

10. Create an approval process

Pricing changes should ideally have a documented process for who supplies, approves and publishes the final advertised price.

Why This Matters for RV Digital Marketing

This development isn’t just a legal or compliance issue.

It can also affect lead quality and advertising performance.

An RV dealer may generate a large number of leads from an attractive advertised price, but if shoppers discover that the actual price is substantially higher, the dealership can end up with:

• Lower lead quality
• Higher sales friction
• More customer complaints
• Poorer trust
• More difficult price comparisons
• Greater compliance risk

Transparent pricing can therefore be viewed not only as a compliance requirement but also as part of a better digital customer experience.

For agencies managing RV dealer PPC, SEO, social media and websites, this means pricing should be treated as a shared data-quality issue, not simply a creative advertising element.

The Bottom Line

The FTC’s new pricing-transparency FAQs represent another important development for vehicle advertising in 2026.

The agency has made clear that it is paying attention to whether advertised prices accurately represent what consumers can actually pay, while also addressing discounts, mandatory fees, optional products, in-transit inventory, representative images and third-party advertising responsibility.

RV dealers should therefore take a close look at how pricing moves from their inventory systems to their websites and ultimately into advertising.

And for RV marketing agencies, the message is equally important:

Accurate pricing isn’t just a dealership responsibility—it needs to remain accurate throughout the entire digital advertising ecosystem.

RVDA is also planning a dedicated session on the FTC’s new pricing and advertising guidance at the 2026 RV Dealers Convention/Expo in Las Vegas, including how dealers can audit digital and print advertising for compliance.