On October 8, 2026, the Federal Trade Commission sued a Florida dealer group and settled with it the same day. Here’s what its complaint alleges: at the group’s Kia stores, from March 1, 2023 through May 6, 2026, over 92% of buyers of cars advertised on CarGurus and Cars.com paid more than the advertised price, and those buyers paid an average of at least $3,354 more. That’s before tax, title, registration, or anything optional.
And the settlement? It pays back nothing. No refunds, no penalty, no admission. The dealers promise to advertise honest prices from here on, and that’s the deal.
I’m not knocking the FTC staff. The case is solid work, and the order has real teeth for the future. But if you’re the buyer who already paid the extra $3,354, a promise about next year’s ads doesn’t get you a dime back. Minnesota law can. Here’s why.
What the complaint says Greenway did
The case is FTC v. Greenway Automotive, Inc., No. 6:26-cv-02337 (M.D. Fla., Orlando Division). It names seven defendants: two Greenway management companies and five dealerships doing business as Greenway Kia at the Avenues, Greenway Kia North, Greenway Kia East, Greenway Kia West, and Greenway Hyundai Orlando. The complaint describes the group as “operating 35+ automobile dealerships”.
Everything in this section is the FTC’s allegation. None of it has been proven, and the order says Greenway neither admits nor denies it. But read the allegations anyway, because the playbook isn’t a Florida invention.
Fees stacked on the advertised number. The complaint says Greenway used “a variety of names” for the fees it kept: “Admin fee”, “Dealer fee,” “delivery fee,” “PTA fee,” “document” fee, “recon” fee, “inspection” fee, “CPO” fee, and “loyalty” fee. Three of them, the dealer, administrative, and PTA fees, were charged “to over 99% of consumers” at the Kia stores and left out of every advertised price.
One couple drove more than an hour for a used 2017 Honda CR-V advertised at $18,800. The price sheet came to $23,539.85. The dealer had added $4,739.85 in its own fees, including a $2,495 “recon” fee. They were told the reconditioning had already been done. The complaint’s answer to that: the car hadn’t even been cleaned, and “there were still toys under the seat.”
The loyalty penalty. The Kia stores allegedly charged “a ‘loyalty’ fee of approximately $995” to anyone who hadn’t bought from that location before. The ad price assumed you were a repeat customer. If you weren’t, you paid $995 more.
The package that can’t come off. Three Kia stores allegedly charged “an extra $2,295 or more” for a dealer add-on package on every new vehicle. The dealership’s own FAQ page said the package was required and “cannot be removed.” It wasn’t in the advertised price.
Paperwork you see after it’s too late. The complaint alleges the dealers closed deals on “a dealer-controlled electronic tablet”. One buyer asked again and again for paper copies. She got a USB thumb drive she “could only open at home.” She’d been charged about $9,000 more than the advertised price, and she didn’t find that out until she was back home.
And a fake prize. Mailers told people they’d won prizes like “$2,500 instant cash” to be collected at a Greenway dealership. According to the complaint, “[t]he prizes shown on these fliers are not real”.
Then my favorite part. On March 11, 2026, the FTC sent Greenway a warning letter saying the agency is committed to “ensuring that the price consumers see in advertising is the actual price they will pay (aside from required government charges, like taxes).” Greenway’s alleged response was to put new banners on its sites: “GREENWAY ALL-IN PRICE” with “ZERO HIDDEN FEES”. The complaint says the hidden fees kept coming. On May 28, 2026, a Kia Sportage advertised at an “all-in” $37,752 came back on a written quote at $39,854.40.
That’s a lot of nerve. The FTC tells you to stop hiding fees, so you advertise that you don’t hide fees.
Why the FTC didn’t ask for the money back
Because it can’t, at least not through the door it walked in.
The complaint was filed under Section 13(b) of the FTC Act, 15 U.S.C. § 53(b), and its prayer for relief asks for a permanent injunction, preliminary relief, and “any additional relief as the Court determines to be just and proper.” No restitution. No refunds. There’s a reason. In April 2021, the Supreme Court held that § 13(b) doesn’t authorize the Commission “to seek, and a court to award, equitable monetary relief such as restitution or disgorgement.” AMG Capital Mgmt., LLC v. FTC, No. 19-508, slip op. at 1 (U.S. Apr. 22, 2021). Justice Breyer put the bottom line plainly: “§13(b) as currently written does not grant the Commission authority to obtain equitable monetary relief.” Id. at 14.
So the stipulated order does what § 13(b) allows. It bans misrepresenting “the costs or terms of purchasing, financing, or leasing a vehicle”, “whether charges, fees, taxes, products, or services are optional or required”, and “whether a consumer has won a prize”. It requires every price ad to show the “Total Price” as “the most prominently displayed item in any visual disclosure”, and it defines Total Price as “the maximum total price, including all mandatory fees or charges a consumer must pay for a motor vehicle,” with only government-required charges left out. Compliance reports, five years of recordkeeping, and ten years of change notices come with it.
That’s a good order for the next buyer. For the 92% who already overpaid, it’s nothing. And as filed, the judge’s signature line is blank. The FTC’s own release notes that stipulated orders “have the force of law when approved and signed by the District Court judge.”
The rule the FTC is enforcing, in one sentence
On September 15, 2026, twenty-three days before the Greenway filing, FTC staff published Automobile Industry Pricing Transparency FAQs. The core of it is one sentence: “the FTC Act requires that the advertised price be the actual price any consumer can walk in and pay.”
The FAQs leave dealers very little room. The only thing that can stay out is a charge “a Federal, State, or local government agency requires the consumer to pay directly.” Everything else goes in, and the FAQs say that “includes dealer-required fees that governments authorize but do not mandate”.
That one lands right on Minnesota. Our documentary fee statute, Minn. Stat. § 168.27, subd. 31(a), caps the fee and says it “may be excluded from the dealer’s advertised price.” The FTC staff’s answer to state doc-fee rules is that they “do not change the fundamental FTC Act requirement that the advertised price must reflect every dealer-required charge”. So a Minnesota dealer can follow the state statute to the letter and still advertise a price the FTC staff calls deceptive. Two caveats. The FAQs say right on page 1 that they’re “the views of FTC staff and [are] not binding on the public or the Commission.” And the cap and its arithmetic are their own subject, which I’ve covered in the doc fee piece.
Minnesota hands the buyer the lawsuit
Here’s the money route the FTC didn’t take in this case, and the one St. Paul already built for the buyer.
The Consumer Fraud Act reaches the ad itself. Minn. Stat. § 325F.69, subd. 1, makes enjoinable “any fraud, unfair or unconscionable practice, false pretense, false promise, misrepresentation, misleading statement or deceptive practice, with the intent that others rely thereon in connection with the sale of any merchandise, whether or not any person has in fact been misled, deceived, or damaged thereby”. A car is merchandise; § 325F.68, subd. 2, defines the term as “any objects, wares, goods, commodities, intangibles, real estate, loans, or services.” And “sale” under subd. 4 includes “any sale, offer for sale, or attempt to sell”. An online listing is an offer for sale. A price on it that the dealer won’t honor is a misrepresentation made so you’ll rely on it. That’s the whole reason it’s there.
The consumer gets damages and fees. Minn. Stat. § 325F.70, subd. 3(a):
In addition to the remedies otherwise provided by law, a consumer injured by a violation of sections 325F.68 to 325F.70, in connection with a sale of merchandise for personal, family, household, or agricultural purposes, may bring a civil action and recover damages, together with costs and disbursements, including costs of investigation and reasonable attorney fees, and receive other equitable relief as determined by the court. An action brought under this section benefits the public.
That last sentence matters more than anything else in this article. In Ly v. Nystrom, 615 N.W.2d 302, 314 (Minn. 2000), the Minnesota Supreme Court held that the general private attorney general statute, Minn. Stat. § 8.31, subd. 3a, “applies only to those claimants who demonstrate that their cause of action benefits the public.” That’s a real hurdle, and the plaintiff in Ly, cheated in a one-on-one restaurant sale, didn’t clear it. In 2023 the Legislature settled it for consumers. Subdivision 3 came in with 2023 Minn. Laws ch. 52, art. 19, § 15, “effective August 1, 2023,” and it “applies to causes of action commenced on or after that date.” A “consumer” is “a natural person or family farmer”. If you bought a car for yourself or your family and you sue after that date, the statute already decided your case benefits the public. You don’t have to prove it.
False advertising is a separate violation. Minn. Stat. § 325F.67 covers any advertisement that “contains any material assertion, representation, or statement of fact which is untrue, deceptive, or misleading,” and it applies “whether or not pecuniary or other specific damage to any person occurs”. By its own terms it’s a misdemeanor and a public nuisance. The private damages route runs through § 8.31, whose subdivision 1 lists “section 325F.67 and other laws against false or fraudulent advertising,” and subdivision 3a, which lets “any person injured” recover “damages, together with costs and disbursements, including costs of investigation and reasonable attorney’s fees”. That route still carries Ly’s public-benefit requirement. A price published to everyone who opens a listing page isn’t a one-on-one deal, but that’s an argument you make. The Legislature didn’t make it for you the way it did in § 325F.70.
And the junk fee law does its own work. Since January 1, 2025, Minn. Stat. § 325D.44, subd. 1a(a), has made it a deceptive trade practice to advertise “a price for goods or services that does not include all mandatory fees or surcharges.” The dealer exemption in subdivision 1b(1) covers only “fees authorized by law”, and the doc fee piece walks through which dealer charges have a statute behind them. I’ve explained how the junk fee law works elsewhere. The catch is the remedy. The Deceptive Trade Practices Act’s own remedy section, § 325D.45, gives an injunction, and attorney fees only where the defendant “willfully engaged in the trade practice knowing it to be deceptive.” It’s not a damages statute.
But it plugs into one. The Consumer Fraud Act now reaches “unfair” practices, and § 325F.69, subd. 8, defines an unfair practice to include one that “offends public policy as established by the statutes, rules, or common law of Minnesota”. The all-in price rule is a statute. So a fee hidden in violation of § 325D.44 is, as I read the text, also an unfair practice under § 325F.69, and that one carries damages and fees under § 325F.70. That’s my reading of the text. Expect a dealer to fight it.
Why a $3,354 case gets filed at all
Do the math the way the dealer does. A buyer overcharged $3,354 has a $3,354 claim. Hiring a lawyer to try it costs more than that. Without fee-shifting, the rational move for the buyer is to complain in a review and go home, and the dealer knows it. Multiply that by every buyer who went home and you’ve got a business model.
Fee-shifting changes that. When the statute puts “reasonable attorney fees” on the losing dealer, the size of the overcharge stops deciding whether the case can be brought. That’s what Minnesota built in § 325F.70, subd. 3, and in § 8.31, subd. 3a. For the longer version of how those two statutes fit together, see the § 8.31 piece and the guide to who actually gets paid under these statutes.
Here’s the concession. Fee-shifting gets a case in the door. It doesn’t win it. You still have to prove the ad said what you say it said and that you paid more than it promised. And most dealer paperwork has an arbitration clause in it, which changes where the fight happens. That’s a separate problem, covered in our piece on the FAA.
What to keep, starting before you leave the house
The Greenway complaint is basically a list of the evidence dealers would rather you didn’t have. Keep it anyway.
The ad, with the date on it. A screenshot of the listing page, including the fine print at the bottom. Greenway’s disclaimer, per the complaint, sat below “multiple screens of unrelated content”. Scroll down and capture it. Do the same with the third-party listing if that’s where you found the car. Listings change. The complaint describes the dealer lowering an advertised price after a buyer complained online.
The price sheet or buyer’s order. Every line item, with its name. “Recon,” “loyalty,” “dealer fee,” “package.” Get the printed one, not a picture of a tablet screen.
The retail installment contract. It states what you actually financed. Check it line by line against the buyer’s order.
Paper copies before you sign. If a dealer won’t give you paper, that tells you something. The buyer in the complaint who got a thumb drive found the $9,000 at home.
The texts and emails. One Greenway sales associate allegedly wrote that the “[c]ash price is a little higher”. If a dealer puts that in writing, keep it.
The FTC did the easy half
The FTC picked the § 13(b) route, and that route doesn’t pay refunds. It wasn’t the only one. The page of AMG I quoted above also says: “Nothing we say today, however, prohibits the Commission from using its authority under §5 and §19 to obtain restitution on behalf of consumers.” AMG, slip op. at 14. The FTC didn’t take that road here. It made one dealer group promise to stop. That has value. But a promise is worth something only to the buyers who haven’t walked in yet.
The buyer who already paid has to make the claim. In Minnesota, the statute gives you the claim, says your case benefits the public, and makes the dealer pay your lawyer if you win. The advertised price is the price. If it wasn’t, keep the ad.
Madgett Law, LLC represents Minnesota consumers in claims under the Consumer Fraud Act, the false advertising statute, and the private attorney general statute, including disputes over advertised prices, dealer fees, and add-ons on vehicle purchases. If you paid more than the price you were shown, send us a message or call 612-470-6529.
Sources: Complaint for Permanent Injunction and Other Relief, FTC v. Greenway Automotive, Inc., No. 6:26-cv-02337 (M.D. Fla. filed Oct. 8, 2026), ECF No. 1, ¶¶ 1–2, 20, 27, 29–35, 47, 54–56, 68–70, 72–74, 76, 83–85, 88, and Prayer for Relief (allegations only); Stipulated Order for Permanent Injunction and Other Relief, id., ECF No. 2-1 (proposed; unsigned as filed), Findings ¶ 3 (neither admit nor deny), Definitions C (“Total Price”), §§ I (prohibited misrepresentations), II (Total Price as the most prominently displayed item), IV (compliance reporting), V (recordkeeping); Federal Trade Commission press release, “FTC Secures Settlement with Auto Dealership Group in Price Transparency Win for Consumers” (Oct. 8, 2026) (2-0 vote; stipulated orders take effect when approved and signed by the district judge); FTC Bureau of Consumer Protection, Warning Letter to Greenway Auto Group (Mar. 11, 2026), at 1; FTC staff, Automobile Industry Pricing Transparency: FAQs (Sept. 15, 2026), at 1 (staff views, not binding), FAQ 2 (government-required charges only; dealer-required fees governments authorize but do not mandate), FAQ 7 (state document-fee rules); AMG Capital Mgmt., LLC v. FTC, No. 19-508 (U.S. Apr. 22, 2021), slip op. at 1, 14; 15 U.S.C. § 53(b); Minn. Stat. § 325F.68, subds. 2 (“merchandise”) and 4 (“sale”); Minn. Stat. § 325F.69, subd. 1 (prohibited practices) and subd. 8 (unfair or unconscionable practice); Minn. Stat. § 325F.70, subd. 3(a)–(b) (consumer private action; damages, costs of investigation, reasonable attorney fees; “benefits the public”; definition of consumer); 2023 Minn. Laws ch. 52, art. 19, § 15 (enacting § 325F.70, subd. 3; effective Aug. 1, 2023, for causes of action commenced on or after that date); Minn. Stat. § 325F.67 (false statement in advertisement); Minn. Stat. § 8.31, subd. 1 (enumerated laws, including § 325F.67) and subd. 3a (private remedies); Ly v. Nystrom, 615 N.W.2d 302, 314 (Minn. 2000) (public-benefit requirement under § 8.31, subd. 3a); Minn. Stat. § 325D.44, subd. 1a(a) (advertised price must include all mandatory fees or surcharges) and subd. 1b(1) (motor vehicle dealer exemption for fees authorized by law); Minn. Stat. § 325D.45, subds. 1–2 (injunctive relief; attorney fees for willful violations); Minn. Stat. § 168.27, subd. 31(a) (documentary fee “may be excluded from the dealer’s advertised price”) — Minnesota Office of the Revisor of Statutes.
This article is general legal information about Minnesota and federal law, not legal advice, and reading it does not create an attorney–client relationship. It describes allegations in a case involving other parties; those allegations have not been proven, and the defendants neither admitted nor denied them. Nothing here predicts how any court would rule on any particular purchase or set of facts. No outcome is promised or implied.