Who has to display the FTC Buyers Guide?

Anyone who sells or offers more than five used vehicles in a twelve-month period — effectively all licensed used car dealers in every state. The Guide must be displayed prominently on or in each used vehicle offered for sale, before and during the offer, not just at signing.

Do I need a Spanish Buyers Guide?

Yes, if you conduct the sale in Spanish — the Rule requires displaying and providing the Spanish-language version in that case. Dealers who negotiate in Spanish must not paper the deal with an English-only Guide. Both versions are freely available from the FTC.

Does selling a car 'As Is' protect me from lawsuits?

It disclaims dealer warranty coverage where state law allows — nothing more. As-Is does not protect against odometer fraud, undisclosed salvage or flood history, or misrepresentation claims, and some states restrict as-is sales entirely. It's a warranty checkbox, not liability armor.

The FTC Used Car Rule and Buyers Guide: What Every Dealer Must Post (and How Dealers Get It Wrong)

The FTC Used Car Rule is one of the few pieces of dealer regulation that is genuinely simple — put the right sticker in the right window with the right boxes checked — and it is still violated on lots every single day, usually out of laziness rather than malice. Since the penalties are federal and calculated per violation, and since state inspectors and plaintiff lawyers both use missing Buyers Guides as easy evidence, this is the cheapest compliance win in the business. Here's the whole rule in plain English.

Who's covered

You're covered if you sell (or offer for sale) more than five used vehicles in a twelve-month period — which means essentially every licensed used car dealer in the country, plus plenty of people who think they're "just flipping." The Rule applies in every state; states can add requirements on top of it (and some do), but no state exempts you from it.

What the Buyers Guide is

The Buyers Guide is the standardized window form the FTC prescribes — a specific federal form, not something your printer designs — that must be displayed prominently and conspicuously on or in every used vehicle offered for sale, at the lot, at an off-site display, wherever the vehicle is offered. The current version of the form dates to the FTC's 2017 revision; use the current form, because the old pre-2017 stock some dealers still print from is itself a violation. It tells the buyer:

Whether the vehicle comes "As Is – No Dealer Warranty" or with a warranty, via checkboxes.
If there's a warranty: whether it's full or limited, what systems are covered, for how long, and what percentage of repair costs the dealer pays.
That the buyer should ask about having the car independently inspected before purchase, and get all promises in writing.
A reference to obtaining a vehicle history report, added in the 2017 revision.

The rules dealers actually trip over

The Guide must be on the car before a customer ever sees it for sale — not produced at signing. "It's in the deal jacket" is a violation with a paper trail.
The signed Guide becomes part of the deal and its terms override contrary provisions in your sales contract. If the Guide says warranty and the contract says as-is, the Guide wins. Give the buyer the final version — reflecting any negotiated warranty changes — at sale.
The Spanish-language requirement: if you conduct the sale in Spanish, you must display and provide a Spanish-language Buyers Guide. Dealers serving Spanish-speaking markets who negotiate in Spanish but paper deals only in English are violating the Rule — and this is an enforcement pattern the FTC has specifically pursued. Stock both versions; they're free to print from the FTC's site.
Service contracts and the "implied warranties" trap: a handful of states don't allow "as is" sales at all or modify implied-warranty disclaimers; the form has a state-specific implied-warranties version for those jurisdictions. Know which regime your state is in.
"As Is" covers warranty, not fraud. Checking the As-Is box does not protect you from claims about rolled odometers, undisclosed salvage history, or misrepresenting condition. Dealers who treat As-Is as a force field learn this in court.

What violations cost

The FTC can seek civil penalties per violation — each car without a proper Guide can count separately — and the statutory penalty amount is adjusted for inflation annually; as of recent years it sits north of $50,000 per violation. Realistically, the FTC pursues patterns rather than single stickers, but state regulators and private lawyers use Buyers Guide failures constantly as the easy, documented violation that anchors a bigger case. A missing Guide is the compliance equivalent of a burned-out taillight: it's the reason the stop happens.

The five-minute compliance system

Print current-version Guides in English and Spanish; keep a stack of each.
Make the Guide part of your recon-to-frontline checklist: no Guide, car doesn't hit the line or the listing photos.
Decide your warranty posture per vehicle deliberately — and make the checkbox match what your F&I paperwork says.
At delivery, have the buyer sign the Guide (where your state uses the signature version) and keep the copy in the jacket.
Quarterly, walk your own lot like an inspector: every windshield, every checkbox.

That's the whole rule. Twenty dollars of printing and a checklist habit versus federal exposure — there is no cheaper insurance in this industry.

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