On November 9, the Federal Trade Commission (FTC) filed a complaint and a proposed stipulated order in the U.S. District Court for the Eastern District of New York against three affiliated New York dealerships doing business as Stream Auto Outlet. The defendants are 324 W Merrick Ave Auto, LLC (Valley Stream), 189 Sunrise Auto Amityville LLC (Amityville), and 2232 Sunrise Hwy Auto LLC (Islip). The FTC brought the action under § 13(b) of the FTC Act and alleged a single count of deceptive advertising of vehicle prices in violation of § 5(a). The defendants neither admitted nor denied the allegations.

The FTC’s Allegations

According to the complaint, the dealerships advertised vehicles online with an “INTERNET SPECIAL” price, but consumers who arrived to buy the car were allegedly told the real price was thousands of dollars higher. The FTC alleged that the advertised price assumed a down payment of several thousand dollars, in one example $3,995, that was disclosed only in fine print. According to the FTC, that language appeared after a consumer clicked a “Details” link and scrolled past a popup, or appeared many screens down the listing page. The complaint also alleges that salespeople confirmed the advertised price by phone without mentioning the down payment, and that consumers were required to buy add-ons not reflected in the advertised price, including a $4,000 warranty financed into the loan, a $1,995 “dealer prep” fee, and, in a later example, a $2,700 LoJack product, a $895 “Theft Protection DNA” product, and a $175 doc fee. The FTC further alleged that the dealerships described the doc fee as “State Regulated” or required by the state, when it is a dealer-imposed fee that New York does not require. In addition, the complaint alleged that price increases were obscured at closing by steering consumers to signature pages of dense, multi-page contracts.

Continued Conduct After Warnings

The complaint stressed that the conduct allegedly continued after warnings. Per the FTC, the dealers received consumer complaints dating back to at least 2022 and that the agency sent a warning letter on March 11, 2026, advising that it is illegal to advertise a price that omits a required down payment, fails to reflect all required fees, is conditioned on dealer financing, or requires additional purchases. According to the FTC, the dealers responded by adding “NO FEES. NO GAMES. JUST CARS.” and a “No Fees Policy” to their websites while continuing the same pricing practices. The FTC characterizes those changes as concealing the conduct rather than ending it. The complaint also frames the harm as competitive, alleging that obscured prices prevent consumers from comparing offers across dealers.

What the Proposed Order Requires

The proposed order permanently bars defendants from misrepresenting the costs or terms of buying, financing, or leasing a vehicle, the availability of vehicles at an advertised price, whether fees, products, or services are optional or required, whether particular financing is required, whether charges were authorized by the consumer, and the amount of any charge, fee, or tax. Its central operational requirement is that whenever the defendants state any amount a consumer may pay to purchase, finance, or lease a vehicle, they must clearly and conspicuously disclose the “Total Price” as the most prominently displayed item in any visual disclosure. “Total Price” means the maximum total price, including all mandatory fees or charges, with only government-required charges excluded. The order’s definition of “clear and conspicuous” is exacting, requiring disclosures that stand out by size, contrast, location, and duration, are unavoidable in interactive media, and are not contradicted or mitigated by other content.

Compliance Obligations

The order imposes sworn compliance reporting, notice of corporate changes for 10 years, and recordkeeping for 5 years, including advertisements, sales scripts, training materials, desk worksheets, signed deal documents, and consumer complaints. It also gives the FTC authority to conduct monitoring discovery and undercover contacts. The order as provided does not include monetary relief.

Takeaways

For dealers, the message is consistent with the FTC’s recent focus on pricing transparency: an advertised price should be the price a consumer actually pays, apart from government charges such as taxes. Similarly, regulators are scrutinizing the disclosures surrounding doc fees, including whether they truly are mandatory. Dealers should review whether their advertised prices depend on down payments, dealer financing, or add-on purchases, whether fees are accurately described as dealer-imposed rather than state-required, whether sales staff give consistent answers on price, and whether documented efforts are made to push Total Price data to all of their advertising channels. A disclaimer in fine print is unlikely to cure a headline price that is not the real one, and a warning letter, as this complaint illustrates, can become the centerpiece of an enforcement action if practices do not genuinely change.