On August 19, the Federal Trade Commission and the State of Connecticut announced a $4 million settlement with Chase Nissan LLC, doing business as Manchester City Nissan. The dealership, its owners, and its managers all signed on. The money goes back to consumers.
Four million dollars is the headline. It is not the lesson.
The lesson is how it started.
One Deal. One Deal Jacket. One Angry Customer.
Every enforcement action in this business starts the same way. Not with a regulator sitting in an office in Washington deciding to go pick a fight with a Nissan store in Connecticut. It starts with a customer at a kitchen table.
A buyer takes delivery. Drives home. Sits down that night and actually reads the paperwork, which is something the industry quietly assumes people will never do.
And they find things.
They find a certification fee on a car the dealership advertised as certified pre-owned. They find a reconditioning charge for work that should have been baked into the price on the window. They find a vehicle service contract billed more than once on the same deal.
So they do exactly what you would want a customer to do. They call the store. They ask for the products to be cancelled. They ask for their money back.
And the finance office gives them the run around.
Nobody cancels anything. Calls do not get returned. The cancellation forms never get processed. Weeks go by.
Then the customer stops calling the dealership and starts calling the state Attorney General.
With screenshots.
That is the entire origin story. A customer who documented everything and refused to go away.
What the FTC and Connecticut Alleged
The FTC and Connecticut sued in January 2024. According to the announcement, the dealership's own data showed customers were frequently charged thousands of dollars in unlawful fees.
Two examples the government called out by name:
Double charging for certification. Some consumers were told they had to pay to “certify” used cars that the store had already advertised as certified pre-owned. You cannot advertise a car as CPO and then sell the customer the certification. That is billing twice for one thing.
Products inserted without consent. Charges like total loss protection were frequently dropped into financing agreements without the customer's knowledge or agreement. Not oversold. Not poorly explained. Inserted.
Connecticut Attorney General William Tong did not soften it. He said the store systematically ripped off Connecticut customers through needless, unauthorized junk fees.
Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection, framed it as part of a larger campaign around price transparency in the auto marketplace. He is not bluffing. In March of this year the FTC sent warning letters to 97 dealership groups nationwide saying the same thing: the advertised price has to be the price the customer actually pays.
What the Order Actually Requires
Read this part carefully, because it is a blueprint for where the whole industry is heading.
The defendants must pay $4 million for consumer redress.
They must stop misrepresenting whether vehicles are certified or carry a limited manufacturer warranty.
They must clearly and conspicuously disclose, as the most prominently displayed item, the maximum total price a consumer has to pay for the vehicle. The only thing they get to leave out is required government charges.
And they must obtain express, informed consent from the customer for every single charge.
Express. Informed. Every charge. Write that on the wall of your finance office.
The Commission vote was 2-0. It was filed in U.S. District Court for the District of Connecticut.
Four Failures That Turned a Complaint Into a Case
Look at what actually happened here, because none of these four things are exotic. I see versions of all of them on store visits.
1. Certification billed twice. If your ad says CPO, the certification cost lives inside the advertised price. Charging it again as a line item is not aggressive F&I. It is double dipping, and it shows up in the data every time.
2. Reconditioning passed to the customer. Recon is a cost of doing business. It belongs in your cost, not on the customer's buyer's order as a separate charge on a car you advertised at a number.
3. The same VSC billed multiple times. This one is not greed. This one is process. Somebody keyed the product twice, nobody caught it in the deal check, and the accounting office funded it. That is a controls failure, and “we didn't mean to” is not a defense when it happens over and over across your book.
4. Cancellations that never got processed. This is the one that turned a bad deal into a federal case. The customer gave the store a chance to fix it. The store did not take it.
That fourth one is the whole ballgame. Numbers one through three cost the dealership a few thousand dollars and an apology. Number four cost them four million.
The CARS Rule Is Dead. It Does Not Help You.
Some of you have been operating under a comfortable assumption since the Fifth Circuit vacated the CARS Rule in January 2025. The FTC formally pulled it out of the federal rulebook in February of this year. No appeal. No re-proposal.
Here is the problem with the comfort.
Manchester City Nissan was never a CARS Rule case. It was filed under Section 5 of the FTC Act, which has been on the books since 1914, and under Connecticut state law. The rule going away changed nothing about the authority that produced this settlement.
If anything, it made things worse for dealers. Without a rule to point at, the FTC went back to case by case enforcement in partnership with state attorneys general. That is a harder target to defend against, because there is no checklist to comply with. There is only what a court decides was deceptive after the fact.
Meanwhile the states are filling the gap. California passed its own version. Massachusetts adopted a price disclosure regulation. Connecticut is clearly awake.
You now have two fronts instead of one.
Your Monday Morning Checklist
Do not read this and nod. Go do these things.
1. Pull thirty deals at random. Compare the advertised price on every one to the final numbers. If they do not match, you have a problem right now.
2. Audit every CPO deal for the last ninety days. Look for a certification charge on a car you advertised as certified. Look for recon.
3. Run a duplicate product report. Same product, same deal, billed twice. Your DMS can show you this in ten minutes.
4. Test your own cancellation process. Have someone call the store as a customer and try to cancel a VSC. Time it. See what actually happens. You will not like the answer.
5. Put a real cancellation SOP in writing. Who takes the request, what form gets used, how fast it goes to the administrator, how the refund gets tracked, and who confirms it back to the customer in writing.
6. Fix your menu. Every product priced, every product initialed, nothing pre-selected, nothing described as included when it is a charge.
7. Train the whole store, not just the box. Sales, BDC, and desk all make representations that end up in the deal jacket.
The Part Nobody Wants to Hear
The owners and the managers were named. Not just the LLC.
Assume every customer has a phone. Assume every conversation gets screenshotted. Assume every online ad you run today will get pulled up eighteen months from now next to a buyer's order.
The good news is that none of this is hard. Disclose the real price. Get real consent. Charge once for one product. Cancel what the customer asks you to cancel, on time, every time.
That is not compliance. That is just running a clean store.
The dealers who figure that out are going to take a lot of market share from the ones who do not.
Let's go to work.
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Frequently Asked Questions
What is the FTC's $4 million settlement with Manchester City Nissan about?
The FTC and the State of Connecticut settled with Chase Nissan LLC (Manchester City Nissan) over allegations of junk fees, including double-billed certification charges, hidden reconditioning fees, and add-on products like total loss protection added without customer consent. The dealership, its owners, and its managers agreed to pay $4 million in consumer redress.
Is the CARS Rule still in effect?
No. The Fifth Circuit vacated the FTC's CARS Rule in January 2025, and the FTC formally removed it from the federal rulebook in February 2025 with no appeal or re-proposal. That does not remove dealer liability: Section 5 of the FTC Act, in place since 1914, and state consumer protection laws still apply, as shown by the Manchester City Nissan case.
What counts as a junk fee in F&I?
Common examples include charging a certification fee on a vehicle already advertised as certified pre-owned, passing reconditioning costs to the customer outside the advertised price, billing the same product (like a vehicle service contract) more than once on a single deal, and adding products to a financing agreement without the customer's express, informed consent.
Can a dealership still get sued for pricing practices without the CARS Rule?
Yes. The FTC and state attorneys general enforce deceptive pricing case by case under existing authority such as Section 5 of the FTC Act and state consumer protection statutes. Several states, including California and Massachusetts, have also adopted their own price disclosure rules, so dealers now face both federal and state exposure.
How can a dealership reduce the risk of a junk fee complaint or investigation?
Make the advertised price match the final price, audit CPO deals for duplicate certification or recon charges, run duplicate-product reports in the DMS, put a written cancellation SOP in place, and require express, initialed consent for every menu product. Most enforcement actions start with an unresolved customer complaint, so a fast, documented cancellation process is the single biggest risk reducer.
Can dealership owners and managers be held personally liable for junk fees?
In the Manchester City Nissan case, the FTC and Connecticut named the owners and managers individually in the settlement, not just the dealership entity. Regulators have shown they will pursue individuals when the same pricing or consent violations occur repeatedly across a store's deals.
This article is for general informational purposes only and does not constitute legal advice. Dealers should consult qualified legal counsel to evaluate their own F&I practices and compliance obligations.
