Compliant Agent Onboarding: California CARS Act

Chaya David
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Overview

The Lead Handling Agent talks with your shoppers directly, which means its language needs to meet the same advertising and disclosure standards your dealership already follows everywhere else. The FTC & California CARS Act step in onboarding is where you review the compliance behavior built into the agent and, if your dealership operates in California, turn on the additional rules required by the state's CARS Act.

 

This isn't a filter that blocks the agent from talking about pricing or offers — it's a set of conversational rules that shape how the agent talks about them, so every conversation stays consistent with FTC guidance (and California law, where it applies) without you having to review each message.

Note: These settings are a safeguard, not a substitute for legal review. Dealers remain responsible for ensuring their advertising and offers meet all applicable federal and state requirements.

How It Works

FTC Compliance (always on)

Every Lead Handling Agent ships with a standard set of FTC-aligned conversation rules already built into its system prompt. These apply regardless of where your dealership is located:

 

System behavior:

  • Don't quote payments, APR, lease offers, monthly payments, special discounts, or financing terms.
  • Pricing & rebates — always present the full advertised price, including all mandatory fees. For rebates or discounts, offer to set an appointment.
  • Don't mention MSRP on its own without the price next to it.
  • Always disclose in-transit vehicles explicitly.
  • Never use the term "ePrice."

 

A Custom Guidelines field under this section lets you add store-specific instructions of your own. Whatever you enter is appended to the agent's existing FTC compliance system prompt — it doesn't replace the default behavior above.

 

California CARS Act (opt-in)

California's CARS Act (SB 766) adds a further layer of state-specific disclosure and conduct rules on top of the standard FTC behavior, and becomes operative October 1, 2026. Because these rules only apply to California dealerships, they're controlled by a single "California dealership" checkbox rather than being on by default.

 

Note: For Dealers located in California - this box is checked and applies by default. For all other dealerships, if "California dealership" is left unchecked, nothing changes — the agent follows only the standard FTC Compliance behavior above.

When checked, the following behavior is appended to the agent's system prompt:

System behavior:

  • Total price — the first time a specific vehicle, a monetary amount, or a financing term is mentioned, include that vehicle's full total price.
  • Add-ons — always note any add-on as optional and not required to buy the vehicle.
  • Financing & preapproval — never state or imply the shopper is preapproved, approved, or guaranteed financing. If asked, offer to set an appointment and let the dealership follow up.
  • 3-day right to cancel — explain only on request. Applies to used vehicles priced $50,000 or less, is void if the vehicle is driven more than 400 miles, and includes a restocking fee. The agent never approves a cancellation itself — it offers to connect the shopper with a sales rep for details.

 

As with FTC Compliance, a separate Custom Guidelines field lets you append store-specific CARS Act instructions of your own.

Where to Find It

This step lives in the onboarding wizard, under the Agents tab: Agents > Configure Agent > FTC & California CARS Act (Lead Handling Agent).

 

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How to Use It

  1. Navigate to Agents in the Onboarding Wizard > Configure Agent > FTC & California CARS Act. https://dashboard.fullpath.com/onboarding-wizard/agents/lead-handling-ftc-compliance 
  2. Review the default FTC Compliance system behavior. No action is required here — it's on for every dealership.
  3. Optionally, add store-specific instructions in the Custom Guidelines field under FTC Compliance.
  4. If your dealership is located in California, check California dealership under the CARS Act section.
  5. Review the California CARS Act system behavior that will be added, and optionally add store-specific instructions in its Custom Guidelines field.

  6. Click Continue to save and move to the next onboarding step.

     

Frequently Asked Questions

Does checking "California dealership" affect leads outside California?

This is a store-level setting. Once checked, the CARS Act behavior applies to that agent's conversations generally — it isn't scoped per individual lead.

 

Can I turn off the default FTC Compliance behavior?

No, the FTC Compliance behavior is standard for every Lead Handling Agent. You can supplement it with your own instructions via Custom Guidelines, but you can't disable the defaults.

 

When does the California CARS Act take effect?

SB 766 becomes operative October 1, 2026.