Devin Daly, co-founder and CEO of Impel, says the FTC’s pricing transparency push is far from over, and dealers who assumed regulatory pressure lifted with the 2025 rule vacatur are now facing a new round of scrutiny. Daly joins us on today’s episode of Inside Automotive, ahead of his panel at the CBT News Auto Leadership Summit on June 16, to break down what has changed, where dealers are getting tripped up and how AI is reshaping compliance from the inside out.
When the Fifth Circuit vacated the FTC’s Combating Auto Retail Scams rule in January 2025, many dealers interpreted it as a sign the regulatory fight was over. However, according to Daly, that reading was wrong. In March 2026, the FTC sent warning letters to 97 dealer groups nationwide, requiring that advertised prices reflect the full, all-in cost to the consumer.
After that, the industry’s response was swift. In June 2026, Cox Automotive paused its good and great price badges on vehicle listings, a move Daly states indicates a broader reevaluation of how pricing information is displayed throughout the retail ecosystem.
“This is an industry-wide shift, it is not over, and it is not just a dealership problem.”
Compliance moved into CRMs
Daly says one of the most common blind spots for dealers is the assumption that FTC compliance lives only in marketing materials and website ad copy. Under current guidelines, any pricing communication from a sales representative, including digital lead responses and BDC conversations, can constitute a pricing disclosure subject to FTC standards.
That shift moves the compliance conversation directly into the CRM and BDC, where AI can play a significant role in maintaining consistency. Daly says enterprise-grade AI platforms, when configured correctly, can ensure that every customer interaction delivers compliant pricing disclosures regardless of who is handling the conversation.
He also highlighted a practical benefit, one in which AI maintains a comprehensive, reviewable record of each interaction. In a regulatory setting where dealers might be required to prove compliance instantly, this record serves as a safeguard rather than a liability.
Daly frames the move toward full pricing transparency not just as a compliance obligation but as an inevitable market condition. Generative AI, Daly believes, has given consumers real-time access to pricing data across the entire market, closing the information gap that historically defined the car-buying experience. Some consumers are now using AI tools to negotiate deals before they ever set foot in a showroom.
Daly says dealers who treat transparency as a cost to absorb are thinking about it the wrong way. Information asymmetry, he argues, was always the original source of consumer distrust in automotive retail. Notably, the FTC rule and consumer AI tools are simultaneously closing that gap from both sides.
Where dealers commonly trip up
According to Daly, the most common compliance failure involves add-on product disclosures. Under current best practices, those disclosures should occur early in the AI-assisted conversation, not on a paper form at the point of signing. Moving disclosure earlier also has a sales benefit, as consumers who are introduced to F&I products before entering the finance office tend to be more receptive to those products, which Daly says supports stronger attachment rates and per-vehicle revenue.
Beyond compliance, Daly argues AI gives dealers a structural advantage in a business defined by constant market shifts. Tariff policy changes, interest rate movements, inventory swings and regulatory updates have made it nearly impossible to retrain human staff fast enough to keep pace. AI, he says, can be updated once and immediately delivers the new messaging consistently across every customer conversation.
Daly will discuss AI, digital retailing and pricing transparency at the CBT News Auto Leadership Summit on June 16 at the Salamander Hotel. Dealers who have not registered can do so here.
