New Motor Vehicle Dealer Price Advertising Guidance
DEALER ADVERTISING RULES COMPLIANCE INFORMATION
Welcome to the Dealer Advertising Rules Training and Information page. This part of our website hosts information and resources designed to help dealers maintain compliance with Oklahoma New Motor Vehicle Commission advertsing rules. The page will be updated periodically to provide insight and focus on advertising rules and enhance the ONMVC's efforts to effectively regulate new motor vehicle dealer advertising, as directed by Oklahoma New Motor Vehicle Franchise Laws - O.S. 47 § 561 et. seq.
DEALER ONLINE PRICE ADVERTISING
In order to provide guidance for new motor vehicle dealer online price advertising, the dealer website vehicle listing example below is offered as a visual representation of how rules-compliant vehicle price information, discounts, rebates, and incentives should be displayed on dealer websites. The example addresses the display of elements such as:
- MSRP.
- Dealer discounts.
- Dealer installed accessories & equipment and addendums.
- Manufacturer rebates & incentives available to all consumers.
- Dealer / documentary fees.
- Selling price available to all consumers (The Most Conspicuous Selling Price).
- Conditional offers consumers may qualify for that must not be included in the most conspicuous selling price.
- The transfer of the selling price all buyers qualify for to 3rd party listing websites such as Autotrader, CarGurus, etc.
The Commission's goal is to regulate dealer advertsing in a way that provides consumers with accurate and transparent pricing and ensures a fair market environment among new motor vehicle dealers for the marketing and sales of new motor vehicles.
Dealer Website Price Listing Example
NOTES ON THE DEALER PRICE LISTING EXAMPLE AND CORRESPONDING RULE REFERENCES
• The manufacturer's suggested retail price must match the MSRP displayed on the vehicle's monroney label. MSRP is an exact price and may not be inflated arbitrarily, or otherwise misrepresented. Rule 465:15-3-6
• Dealer installed accessories & equipement including, but not limited to items such as spray-on bedliners, nitrogen in tires or interior /exterior protection products must be included in the online vehicle listing price. These hard-add accessories must also be listed on an addendum label which is attached to the vehicle near the Monroney label. The hard add accessories may be itemized individually or may be listed as a "package" of accessories. Rule 465: 15-3-7 and ONMVC statutes: O.S. 47 Section 565 A (5) (a)
• Dealer discounts must be available to all customers and cannot contain hidden, selective or conditional rebates. Rule 465: 15-3-7
• Rebates or incentives included in the most conspicuous selling price must be available to all consumers. Rule 465: 15-3-7
• Dealer/ documentary fees must be disclosed in the price stack / math box. The only fees that may be excluded are state fees and taxes. Rule 465: 15-3-7
• The most conspicuous price is to be presented in a way that clearly identifies it as the price for which any consumer may purchase the vehicle. The most conspicuous price is the price that must be distributed to 3rd party websites, and cannot contain conditional or selective rebates or incentives, whether provided by the manufacturer or the dealer. Rule 465: 15-3-7
• Savings or total savings claims must be mathematically consistent with price reduction from MSRP and may only include legitimate discounts, rebates or incentives available to all customers. No conditional offers may be included. Rule 465: 15-3-7
• Dealer-sponsored trade assistance and/or finance assistance must be placed below the most conspicuous price with “Other offers you may qualify for” and must not carry over to 3rd party websites. Rule 465: 15-3-7 (d)
• Selective and/or conditional manufacturer rebates & incentives must be placed below the most conspicuous price with "Other offers you may qualify for” and must not carry over to 3rd party websites. Rule 465: 15-3-7 (d)
This section will be updated periodically and expanded to include guidance for other advertising rules as needed.
Social Media Compliance Tools
The Advertising Rule Enforcement Process
The Commission adopted a new penalty scale, effective January 1, 2026, to enforce advertising violations. Some violations require a warning letter while other violations require an immediate fine via the Informal Complaint Resolution. Depending on how many times a dealer has received violations or the aggregious nature of the violation, the Commission can file a Formal Complaint which includes a Notice of Hearing. Warning letters will be sent via email and regular mail. Informal Complaints will be sent via certified mail. Formal Complaints will be sent via certified mail and by email to the dealer and dealership executive manager, if one exists.
INFORMAL COMPLAINT RESOLUTION PROCESS
The Informal Complaint Resolution is an attempt to resolve the matter without the necessity of a Hearing. A dealer has a choice to accept or reject this offer. If rejected, the Dealer must request a hearing in writing.
FORMAL COMPLAINT PROCESS
The Formal Complaint is accompanied by a Notice of Hearing sent certified mail. When a Hearing is scheduled, the dealer will be provided the opportunity to be heard and will be provided all rights afforded by the Oklahoma Administrative Procedures Act. Dealers must be represented by an attorney in Hearings at their own expense. *Massongill v McDevvitt, 1989 OK CIV APP 82.
Questions about enforcement documents can be communicated to the Executive Director or Deputy Director.
CONSENT ORDERS
Consent Orders are another option at the Commission's disposal. They can be offered at a higher fine level, than the penalty scale, for more aggregious violations. The ONMVC staff makes every effort to produce Consent Orders acceptable to the Commission, but there may be occasions when the Commission chooses to reject a Consent Order, even if it has been accepted by the dealer. The Commisson may decide to request additional information, increase / decrease penalty amounts, or may decide to reject an Order altogether and proceed to a Hearing. These decisions are within the authority of the Commission as provided by O.S. 47 § 563 (F).
ENFORCEMENT ACCORDING TO A PENALTY SCALE
Enforcement of advertising rules will be administered according to Parts 1 and 2 of the penalty scale shown below..
The ONMVC Advertising Rule enforcement penalty scale consists of 2 PARTS. Each part is based on a specific set of rules.
PART 1 consists of 3 steps and features specific fine amounts. Informal Complaint Resolutions or Consent Orders are offered at the ONMVC's discretion. A Hearing may be called for any enforcement step level. PART 1 does not include a warning step.
| Enforcement Level | COMMISSION ACTION | |
|---|---|---|
| Level 1 - First Enforcement Step | Informal Complaint Resolution | $3000 Fine or Consent Order |
| Level 2 - Second Enforcement Step | Informal Complaint Resolution | $6000 Fine or Consent Order |
| Level 3 - Third Enforcement Step | Notice of Complaint and Hearing | Automatic Hearing |
PART 1 applies to the following advertising rules: 465: 15-3-4 Bait advertisement (insincere pricing), 465: 15-3-6 Manufacturers suggested retail price, 465: 15-3-7 Dealer price advertising. Each rule violation is enforced and tracked separately. The penalty history for violations of Part rules will reset after one year, per rule, if there have been no further violations. The ONMVC may offer a Informal Complaint Resolution or Consent Order at any level but is not obligated to do so. A hearing may be called at any enforcement level.
PART 2 features an initial "Warning Step" with a opportunity to cure the violation. When an ONMVC investigator discovers a PART 2 rule violation, a warning is sent to the dealer. The dealer is provided 48 hours to cure the violation. Cure progress will be monitored, but the dealer is responsible for notifying the ONMVC when the advertising violation has been cured. If not cured within 48 hours, enforcement moves to the Level 1 enforcement step within PART 2, and a complaint is sent to the dealer. Further violations of the same rule will move the dealer through enforcement scale Levels 2 and 3. Informal Complaint Resolutions or Consent Orders are offered at the ONMVC's discretion but a hearing may be called for any enforcement step level. PART 2 also now features fixed Fine amounts.
| Enforcement Level | COMMISSION ACTION | |
|---|---|---|
| Warning Step. Dealer provided 48 hours to Cure Uopn Notification | Warning Letter and Email Sent to Dealer | Commission Review. Dealer must provide proof of complaince. If the violation has not been cured within 48 hours, the case proceeds to the Level 1 - Forst Enforcement Step. Any further violation of the specific rule within one year and next enforcement action for that rule begins at Level 1. |
| Level 1 - First Enforcement Step | Notice of Complaint and Hearing | Offer of $3,000 Consent Order at the ONMVC's discretion. |
| Level 2 - Second Enforcement Step | Notice of Complaint and Hearing | Offer of $6,000 Consent Order at the ONMVC's discretion. |
| Level 3 - Third Enforcement Step | Notice of Complaint and Hearing | No offer of Consent Order. Automatic Hearing. |
Part 2 applies to the following advertising rules: 465: 15-3-2 Avaialbility of vehicles, 465: 15-3-3 Accuracy (Disclosures & Disclaimers), 465: 15-3-5 Layour, 465: 15-3-8 Identification, 465: 15-3-10 Auction, 465: 15-3-11 Authorized dealer, 465: 15-3-12 Lease advertisements, 465: 15-3-13 Closed ended credit terms, 465: 15-3-14 Prohibited statements, 465: 15-3-15 Dealership name, 465: 15-3-16 Number one claims (Proposed new rule). Each rule violation is enforced and tracked separately. The penalty history for violations of Part 2 rules will reset after one year, per rule, if there have been no further violations. The ONMVC may offer a Consent Order at any level but is not obligated to do so. A hearing may be called at any enforcement level.
