What this checklist covers
The Federal Trade Commission’s Used Car Rule requires dealers who sell more than five used vehicles in a 12-month period to display a Buyers Guide on every used vehicle offered for sale. The guide tells shoppers whether the vehicle comes with a dealer warranty or is sold “as is”, and it becomes part of the sales contract. Maine and Wisconsin use their own forms.
The FTC Used Car Rule Checklist is a 15-point scorecard for Buyers Guide display, warranty disclosure, as-is terms, dealer warranty terms, customer acknowledgement, and used vehicle sales documentation. Each criterion is scored from 1 to 5 on what the auditor sees on the day, and every gap goes into an action plan with an owner and a close date.
AutoSmart tip: FTC Used Car Rule compliance is straightforward but frequently non-compliant in practice — the most common failures are Buyers Guides missing from vehicles, Buyers Guides using outdated forms, and ‘as is’ vehicles where sales staff make verbal warranty representations that contradict the displayed Buyers Guide. Conduct an unannounced lot audit at least monthly: walk the used vehicle lot and check every displayed Buyers Guide for presence, correct format, and accurate completion.
The checks
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Buyers guide display and content
- Is a completed Buyers Guide displayed in the side window of every used vehicle offered for sale on the dealer's lot, as required by the FTC Used Car Rule?
- Is the Buyers Guide using the current FTC- required format — including the updated Spanish-language option for Spanish-speaking customers — rather than an outdated version predating recent rule amendments?
- Is the Buyers Guide visible and legible from outside the vehicle, displayed in the window so the required disclosures can be read without entering the vehicle?
- Are Buyers Guides removed from vehicles only after a sale is finalised — not removed during test drives or customer inspections in a way that creates a gap in compliance during the sales process?
Warranty and as-is disclosure
- Where a vehicle is sold 'as is', is the 'As Is — No Warranty' box on the Buyers Guide correctly checked, with no implied or verbal warranty statements made by sales staff that contradict the as-is disclosure?
- Where the dealer offers a warranty, is the warranty box on the Buyers Guide checked and the specific warranty terms described — covering systems covered, duration, and the percentage of repair costs covered by the dealer?
- Where a manufacturer's warranty is still in effect on the used vehicle, is the Buyers Guide accurately reflecting this — with staff able to explain the remaining coverage to the customer?
- Is the Buyers Guide consistent with any written warranty document provided at the time of sale — with no discrepancy between what the Buyers Guide discloses and what the customer's written warranty document says?
Customer acknowledgement
- Is the customer given a copy of the Buyers Guide to keep at the point of sale — with the customer's signature confirming receipt obtained on the dealer's copy?
- Is the customer's signed copy of the Buyers Guide retained in the deal file — providing evidence of compliance if a dispute or FTC inquiry arises?
- Where the sale terms differ from what the Buyers Guide originally disclosed (e.g., dealer agrees to provide a warranty on a vehicle initially listed as-is), is the Buyers Guide updated and re-signed before the sale is finalised?
Documentation and governance
- Is the completed Buyers Guide retained in the deal file for every used vehicle sold, with the vehicle's VIN, sale date, and dealer's warranty terms confirmed as matching the deal documentation?
- Are used vehicle sales staff trained on the FTC Used Car Rule requirements — specifically on when a Buyers Guide must be displayed, what must be disclosed, and the consequences of non-compliance?
- Is Buyers Guide compliance reviewed through a periodic lot audit — physically checking that every used vehicle on the lot has a correctly completed Buyers Guide displayed in the required position?
- Is FTC Used Car Rule compliance included in the dealership's regular compliance calendar, reviewed at defined intervals rather than only when a complaint or FTC inquiry is received?
How to run it
How the scoring works
Before the visit, fill in the dealer or centre, the auditor, the date and the audit cycle. Then score each of the 15 checks from 1 to 5 on what you see on the day, not on what the site aims for, and add them up out of 75.
- 1Not in place
- 2Attempted
- 3Defined
- 4Managed
- 5Fully sustained
- Green60–75 · 80–100%Compliant. Keep the standard.
- Amber38–59 · 50–79%Improvement needed: a structured action plan within 30 days.
- Red0–37 · Below 50%Priority intervention, escalated to regional management.
Then close every gap
Each gap goes into the action plan tracker and moves through four stages until the auditor closes it.
- 1PendingOwner and close date set
- 2In progressWork under way, evidence gathered
- 3CompletedEvidence submitted for review
- 4ApprovedVerified and closed by the auditor
Questions about this checklist
Which dealers does the FTC Used Car Rule apply to?
Dealers who sell more than five used vehicles in a 12-month period, in every state except Maine and Wisconsin, which have their own forms. Check the FTC’s guidance for the exact scope.
Does a vehicle sold “as is” still need a Buyers Guide?
Yes. Every used vehicle offered for sale needs a guide; “as is” is one of the boxes on it.
How often should the lot be checked?
Weekly is a common rhythm, plus a check whenever new used stock arrives, because a single unlabelled vehicle is a violation.
