Q: What are FTC expectations about the use of hyperlinks and disclosures?
A. Hyperlinks that are not clearly marked as credit terms, general statements like “not all customers will qualify” and “see dealer for details” are not going to be acceptable. Disclosures in media must be visible long enough or in a cadence for consumers to see or hear and understand them and I see many TV and YouTube ads where this is not the case.
Q: How should ads handle payment amounts for a credit sale or lease?
A: Dealers need to know that advertising any payment amount for a credit sale or lease triggers a requirement to disclose other terms…that this is the first thing the FTC looks for. Customers should be able to determine if they qualify for the advertised offers so including minimum credit scores is an advisable practice.