During the MDA Chair's Tour, members raised questions with MDA President Gerald Wood regarding dealer website banner ads, advertised prices for cash-back, and low-APR options. Gerald recently met with the AMVIC team to get detailed answers.
Dealer Website Banner Ads – AMVIC had advised us they have been seeing several situations where a dealer’s ad disclosures were compliant, with the exception of banners that were added to the dealer’s homepage. Often, the required disclosure for an advertisement was not included. These banners are considered to be advertisements, per the Automotive Business Regulation, and therefore need to meet the regulatory requirements. In our meeting, the question was asked to have AMVIC clarify how to include those disclosures properly.
- AMVIC has advised us that if the required disclosures are included in a clickable “pop-up,” they would be comfortable with the approach. We were cautioned that they would be concerned if the click-thru took the consumer to a stand-alone page, away from the original banner ad.
Advertised Price for Cash Back and Low APR Options – we are seeing manufacturers test the ability to offer a cash-back or low APR option in their incentive marketing. The strategy creates a challenge in being compliant with the All-In Price laws here in Alberta. Most dealers are using the cash-back price as the lead offer but if the consumer chooses the low APR option, the price on the bill of sale will show significantly above the all-in price.
- AMVIC was aware of this situation and has confirmed that there is a path to advertising such that the dealer is compliant with the regulation. The direction has been to advertise both prices, along with the required disclosures for a low APR option. AMVIC’s position has been that if everything is disclosed, the dealer should be compliant.
If you would like more assistance in understanding the comments above, please call the MDA Office.