The FTC's big dealership rule, the one that would have banned bait-and-switch pricing and junk fees nationwide, is dead. A federal appeals court killed it in January 2025, and in February 2026 the FTC formally withdrew it. But the story didn't end there. In 2026 the FTC told dealers exactly what it expects anyway, started sending warning letters, and kept collecting eight-figure settlements. So what rules actually govern a New Hampshire car deal today, and which Granite State dealers are already pricing the way the FTC says they should? We checked their own websites.
The rule that died
The Combating Auto Retail Scams (CARS) Rule, finalized in December 2023, would have required dealers to advertise an "offering price" (the real price any consumer could pay), banned charges for add-ons that provide no benefit, and required express informed consent for every extra charge. On January 27, 2025, the Fifth Circuit vacated the rule in NADA v. FTC. The court never judged the rule's substance; it held that the FTC had skipped a procedural step its own regulations require. The FTC did not appeal, and on February 12, 2026 it withdrew the rule from the Code of Federal Regulations. As of this writing there is no successor rule, and none has been announced.
The standard that replaced it
What binds dealers now is what bound them before: Section 5 of the FTC Act, which prohibits unfair or deceptive acts and practices, plus a set of older rules that never went away: the Used Car Rule (the Buyers Guide on every used car), the GLBA Safeguards Rule (dealers' data-security duties), and the Regulation Z and Regulation M advertising triggers for credit and lease offers.
What changed in 2026 is that the FTC spelled out precisely how it reads Section 5 on price advertising. On March 13, 2026 it sent warning letters to 97 dealer groups covering more than 200 locations, including AutoNation, Lithia, and Group 1. On September 15, 2026 its staff published FAQs stating the standard plainly:
- The advertised price must be the price any consumer can walk in and pay.
- All mandatory dealer fees go inside that price. The FTC's own example: a $40,000 car with an $85 doc fee must be advertised at $40,085.
- Only government-required charges (tax, title, registration) may sit outside it.
- The all-in price must be the most prominent figure: no financing-conditioned headline prices, and no rebates that aren't available to everyone.
Staff FAQs are guidance, not a binding rule. But they describe the standard the FTC is actively enforcing, as the dealers below learned.
What getting it wrong looks like
The recent enforcement record is not subtle. Leader Automotive Group (AutoCanada) paid $20 million, the largest penalty ever imposed on a dealer group, for bait-and-switch pricing, charging roughly 80% of buyers for add-ons they hadn't agreed to, and posting fake reviews. Lindsay Automotive paid $3.1 million. And on October 8, 2026, the FTC sued Greenway Automotive Group after the group ignored its warning letter; the agency says more than 92% of Greenway's buyers paid over $3,350 above the advertised price.
New Hampshire has one major case of its own, brought by the state: in December 2022 the Attorney General settled with DMO Auto Acquisitions, doing business as Dan O'Brien Kia of Concord, for $1.25 million. The allegations ran well past pricing: a fictitious "credit repair program," incomes inflated on loan applications, a forged signature, and products enrolled over a customer's express refusal, and the settlement imposed five years of injunctions and an independent monitor. No FTC action from 2023 to 2026 names a New Hampshire dealership. In September 2026 New Hampshire also joined a multistate settlement with Credit Acceptance ($694 million nationally; about $786,343 to New Hampshire consumers) built in part on allegations of dealers packing payments.
New Hampshire law, briefly
The state layer is RSA 358-A, New Hampshire's Consumer Protection Act: it bans unfair and deceptive practices, allows the Attorney General to seek up to $10,000 per violation, and gives consumers private suits with two-to-three-times damages for willful violations. What New Hampshire does not have: a cap on documentation fees, and any state rule requiring dealer fees inside advertised prices. (Massachusetts, by contrast, has a real all-in advertised-price rule, 940 CMR 5.02(3).) A claim circulating online that New Hampshire caps doc fees at $27 cites no statute, because there isn't one. The average doc fee charged in New Hampshire is about $604, per CarEdge's 2026 State of Dealer Fees study (449 verified quotes across 113 dealers, ranging from $100 to $1,199).
The transparency test: New Hampshire dealers, checked October 13, 2026
There is no government registry of "compliant" dealers, and most of what the rules govern (consent at the finance desk, the Buyers Guide on a used car, data security) can't be seen from outside a dealership. One piece of the FTC's standard can be checked by anyone: whether the mandatory doc fee sits inside the price on the dealer's own vehicle pages. So we opened the new-vehicle pages of New Hampshire dealers and did the arithmetic. Filter by how they present it:
MacMulkin Chevrolet, Nashua
$464 doc fee
The benchmark match. On the MacMulkin vehicle page we checked, the stack reads MSRP $57,205, minus a $10,000 MacMulkin discount, plus a $464 Documentation Fee line, landing on a single FINAL PRICE of $47,669. The fee is itemized and inside the price a shopper sees. Google rating: 4.5 stars from 2,282 reviews.
Quirk Buick GMC Manchester
$499 doc fee
Slightly higher Documentation Fee, but 100% complies with FTC guidelines. Quirk Buick GMC Manchester put the $499 doc fee as its own line inside the displayed Quirk Price (for example, a GMC Acadia at Buick GMC: $55,645 − $7,154 + $499 = $48,990). Google ratings: Buick GMC 4.5 (957).
MacDonald Motors Ford, Center Conway
$649 documentation fee
The listing page shows no fees at all, but the vehicle detail page breaks out a $649 Documentation Fee as its own line and includes it in the math: $62,870 MSRP, minus a $3,491 dealer discount, plus the $649 fee equals a $60,028 adjusted price, before rebates. Fee itemized and inside the final figure.
AutoFair: Ford (Manchester) & Volkswagen (Nashua)
$799 dealer fee
Every listing and vehicle page carries a "Transparent Price including all dealer fees" line: the $799 dealer fee is folded into that price, which flows into the final price. What you don't get is a break-out: the fee never appears as its own line. And at the Ford store, the fine print excludes a $999 "AutoFair Advantage Plus" package fitted to new vehicles from the online price. That is the kind of exclusion the FTC's standard is written against. Google ratings: Ford 4.5 (4,223), Volkswagen 4.6 (3,070).
Peters Nissan of Nashua
$589 admin fee
Halfway there. The page states its $589 admin fee is included in the Total Price, the fee-inclusive presentation the FTC wants. But the same total also bakes in a $189 wheel-locks charge on the base Sentra we checked: an add-on the shopper never chose, included in every price. Transparency about the fee, yes; a clean all-in price, not quite.
Banks Chevrolet, Concord
$196 doc fee
The lowest doc fee we found in New Hampshire, and it is itemized right in the price stacks on Banks's inventory listings. The gap is on its specials pages, where the fee disappears: the lease offers' fine print never mentions it. Where you look determines what you learn. Google rating: 4.6 stars from 4,894 reviews.
Grappone Toyota, Bow
$649 administration fee
Grappone publishes its $649 administration fee on a dedicated page, more disclosure than most dealers offer, alongside published upfront-pricing and negotiation-free policies. But the same page states the fee is "separate from our upfront price": disclosed, plainly, and deliberately not included. Under the FTC's September standard, that's the line.
Beyond the seven above, other New Hampshire dealers publish their fee amounts in website disclaimers without putting them in the headline price: Tulley ($599), McGovern's New Hampshire stores ($595), Portsmouth and Rochester Volkswagen ($599), Dover ($599), Irwin ($764), and Key Auto Group's stores ($899, the highest we found in the state). And one cautionary example: Betley Chevrolet's own website contradicts itself, showing a $163 administration fee in its price stacks and $190 in its disclaimer. When a dealer's site can't agree with itself, believe neither number until it's in writing.
What this test can't tell you. A doc fee inside the advertised price is a presentation signal, not a compliance certificate. Add-on consent, finance-desk conduct, Buyers Guide display on used cars, and data-security practices are invisible from a website: the Dan O'Brien Kia violations ran for years before the Attorney General's settlement made them public, and none of them could have been spotted online. The absence of an enforcement action is not proof a dealer is clean, and a fee in the price is not proof a dealer is honest. It is, however, the one part of the FTC's standard any shopper can verify before ever visiting a showroom, which is exactly why the FTC wrote it that way.
How to shop New Hampshire under this standard
- Ask whether the doc fee is in the online price. It's a yes-or-no question, and the dealers above who answer "yes" publish the proof on every vehicle page.
- Get the out-the-door number in writing (price, fees, tax, title, registration) before discussing financing or trade-in. Under RSA 358-A, a price that changes at the desk isn't just annoying; it's the fact pattern the Consumer Protection Act exists for.
- Treat pre-installed add-ons as negotiable or walk-away items. If a charge is already baked into every car's total (wheel locks, protection packages), you didn't consent to it by showing up.
- Remember the fee itself is uncapped in New Hampshire. The amount is a real difference between dealers: $196 to $899 across the state, on identical paperwork. It's fair game in your comparison, and our doc-fee ranking for Massachusetts and New Hampshire shows how the region stacks up.
- Complaints go to the NH Attorney General's Consumer Protection Bureau (RSA 358-A), the office that brought the Dan O'Brien case.
Related on CarThrive
- Dealer Doc Fees in Massachusetts & New Hampshire: Who Charges What
- Best Chevy Silverado 1500 Lease Deals in October 2026 Around Manchester, NH
- Best Chevrolet Dealerships in Concord, NH
- Best Chevrolet Dealerships in Manchester, NH
Sources
- FTC, CARS Rule withdrawal, Federal Register (91 Fed. Reg. 6507, February 12, 2026); NADA v. FTC, 127 F.4th 549 (5th Cir., January 27, 2025)
- FTC, dealer warning letters (March 13, 2026) and Business Center staff FAQs on advertised pricing (September 15, 2026)
- FTC, Leader Automotive Group / AutoCanada settlement ($20 million) and Greenway Automotive complaint (October 8, 2026)
- NH Attorney General, DMO Auto Acquisitions LLC d/b/a Dan O'Brien Kia settlement (December 27, 2022); NH RSA 358-A
- Credit Acceptance multistate settlement (September 18, 2026)
- CarEdge, State of Dealer Fees 2026 (New Hampshire average doc fee, $604)
- Dealer vehicle pages checked live on October 13, 2026: MacMulkin Chevrolet, MacDonald Motors Ford, Quirk Chevrolet of Manchester, Quirk Volkswagen of Manchester, Quirk Buick GMC of Manchester, AutoFair Ford, AutoFair Volkswagen of Nashua, Peters Nissan of Nashua, Banks Chevrolet, Grappone Toyota