FTC Compliance

Chaya David
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Overview

The FTC enforces advertising requirements for automotive dealers, including rules related to pricing, add-ons, and vehicle availability. At Fullpath, we design our products and practices with these requirements in mind, helping dealerships navigate regulations with greater confidence.
 

This article explains the approach behind Fullpath's FTC compliance work and what it means for how you'll use the platform going forward.
 

Compliance risk shows up in two places: in the offer data itself (pricing, lease and finance terms, inventory status) and in the content built around that offer — the email, SMS, ad copy, or landing page language your team writes, or an AI system generates on your behalf. Fullpath is addressing both, with a shared compliance engine that plugs into each product.
 

Note: Compliance validation is a safeguard, not a substitute for legal review. Responsibility for FTC compliance rests with each dealership — Fullpath's tools, controls, and validations are designed to support and streamline your active oversight, not replace it.

How It Works

Fullpath's approach to FTC compliance operates at two layers:
 

1. Source-Level Offer & Inventory Validation

Lease, finance, and OEM offers are validated at the source — before they're ever pulled into a customer-facing message — so every downstream product is working from clean data. This layer includes:

  • All-In Pricing: Fullpath enables dealerships to advertise the full price a buyer pays (excluding government tax & fees) by sending it directly through their inventory feed. Alternatively, dealers can send the base price through their feed and list fees separately, allowing Fullpath to calculate and advertise the full price in accordance with regulations. Learn more
  • Offer Validation (available by September 16, 2026): An integrated setting that, when turned on, only advertises offers that include FTC-compliant fields across all Fullpath activation solutions.
  • Inventory Validation: Fullpath automatically checks and validates that vehicles are actively in inventory before enabling or distributing advertisements across supported channels. Learn more
  • In-Transit Vehicles (available by September 16, 2026): Fullpath will automatically label in-transit vehicles in Audience Activation's email campaigns, Website Engagement's widget, and Dynamic Payment's specials page. These vehicles are excluded from Audience Activation's SMS campaigns. In Digital Advertising, dealers will be able to opt to exclude them, since the "in-transit" label can't be guaranteed there.

2. Content-Level Checks for Editable, Open-Text Fields

Anywhere your team (or an AI assistant) writes free-form copy — a custom email, an SMS message, ad creative — Fullpath applies AI-powered compliance checks before that content goes live.

  • Ad Copy Review: Fullpath offers AI-powered compliance reviews for custom campaigns in Digital Advertising, VINs Acceleration, and Audience Activation (email and SMS). The checker is grounded in FTC guidance and flags language that can increase compliance risk — a missing loan term, a lease payment presented without required disclosures, pricing language that doesn't match the underlying offer, and similar patterns. It's built to surface findings so you can revise before publishing; it's an aid and does not guarantee compliance, so it's always advised to consult your legal team before publishing. Learn more
  • AI Agent Compliance: Fullpath's Lead Handling Agent and Audience Activation's two-way SMS Agent are designed for FTC compliance by default when handling sensitive topics in conversations. Dealerships can adjust the Lead Handling Agent's operating instructions to match their needs and preferences. Learn more
Note: Compliance checks are designed to look at merge tags and dynamic content the same way they look at plain text — a merge tag that would render a non-compliant value is flagged just as if that value had been typed directly.

Frequently Asked Questions

Does this replace my dealership's legal review process?

No. Fullpath's compliance checks are designed to catch common, well-defined issues automatically and reduce risk — they don't replace your dealership's own legal or compliance review process.
 

Will a flagged message be blocked from sending?

Compliance checks are designed to surface findings so your team can review and revise content before it goes out, rather than blocking you outright. Exact behavior will vary by product as each rolls out — check your product's specific workflow for details.
 

Can I still write custom offer language?

Yes. You'll still be able to write custom email, SMS, and ad copy. The compliance checker reviews what you write and flags specific issues rather than restricting what you're able to enter.