Advertising Compliance - Dodging Bullets

I remember the good old days when I wasquite well. So, what's the problem?
blissfully ignorant about everything except makingWell, the ad was "questionable" in all kinds of
the next car deal.ways, such as:
Back in the days when I was a dealership general• Proclaimed that the dealer "used $23 million
manager, I couldn't wait for the next big sale,from 18 banks to revive the local credit market
promotion, mailer, etc, whatever it took to makeduring this sale" and that we had a "partnership
things happen. I gladly signed up for whateverlocal banks for a special credit and pricing event" -
"Next Big Thing" my boss was willing to pay for.sorry, but we didn't have any deals with any
After all, we had to keep the staff pumped upbanks for any amount of money.
and the customers coming in, right?• Stated that these "banks" were offering us
Well, since then I've learned a thing or two about"preferred terms that our competitors couldn't
compliance and now realize that many of thematch in this market" - yeah, sure...
programs we participated in were questionable at• 3.9% APR available on certified pre-owned
best or downright misleading (and thus, illegal) atvehicles - too bad we didn't have any CPO cars...
worst. I never gave those advertisements a• Vehicle payments advertised that virtually no
second thought because I figured we paid theone would qualify for: 60 month financing on an 8
program vendors a lot of money so they mustyear-old car with $29 down and an amount
be legal and proper, right? And even if the adsfinanced of less than $5,000... Good luck with that.
were improper, the vendor would be responsible,(I don't know, maybe one of those 23 phantom
not us, right? Ah, wrong and wrong.banks that I allegedly hooked up with would have
There was one program that we did that stilldone that kind of a deal?)
gives me night terrors when I think about it. IAs far as I'm concerned, I - and the dealer -
was GM at a dealership that was part of a groupdodged a bullet with that ad. The worst part, of
in California and I got the word from thecourse, being the "I" part. My name, my picture
corporate office that we signed up for aand my "quotes" were all over the ad. Was I
promotion with a company from another state. Itpotentially liable for any violations? Heck yeah!
went something like this: the company sent outAdvertising is considered deceptive if "members
mailers which were simulated newspaper ads withof the public are likely to be deceived" or the
my picture and all kinds of exciting quotes fromadvertisement has a "tendency or capacity to
me about this amazing sale we were putting on.mislead the public". If an ad is deceptive, an
Now the really exciting part was that these adsadvertiser has liability regardless of whether there
were mailed to people in hand-addressedwas intent to deceive. A dealer has the duty to
envelopes, so they were more likely to open it.investigate the accuracy of any statements made
When the addressee opened the envelope, he orin advertising. You should never assume that
she found the "newspaper ad" with a Post-it noteadvertising agencies or representatives know all
stuck to it signed by "J", an apparent friend ofthe laws and regulations governing advertising
theirs who saw the ad and thought they would becompliance. This is particularly true of companies
interested.based in other states, such as internet and direct
I loved it! I thought this was a great marketingmail providers. State advertising laws are very
concept. Everyone knows someone with the firststringent and the responsibility for compliance lies
initial J, so it had a certain degree of credibility. Ofwith the dealership, not the advertising agency.
course, a few customers were a bit savvier andBottom line: Be careful when advertising. If you're
called the dealership to express their disgust withnot sure about an advertisement or promotion,
our "sleazy tactics", but I digress.it's a good idea to have an attorney look it over.
At any rate, I was excited, the staff wasIt's probably better than trying to dodge those
excited, and, not surprisingly, the promotion didbullets.