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How to properly advertise a manufacturer's offer of a 'matching' down payment

November 23, 2010
Various matching down-payment offers have been promoted in vehicle manufacturer advertising in recent months. The Illinois attorney general's office and the Better Business Bureau raised concerns about such advertising and asked the CATA and the IADA to remind dealers of the proper means to advertise such offers. In a situation where a factory offers to match a customer down payment and also allows the customer to use existing rebates as the down payment, dealers and factories may advertise as shown in Box 1, in a clear and conspicuous manner. Dealers also may advertise as shown in Box 2. The rebate must be available to all customers. That is, it cannot be limited like a Farm Bureau rebate. The attorney general's office will consider the matching down payment program as a "limited rebate" in the following circumstances: 1. If there is no rebate for that vehicle; 2. If the factory will not permit the rebate to be used as a down payment; 3. If the rebate is less than the matching down payment program maximum (i.e., $1,000); 4. If 0% financing (or any financing) is advertised as an alternative to the rebate. Dealers and factories cannot use advertisements which lump limited rebates with general rebates, deduct limited rebates from the price of a vehicle, or base credit/lease payments if a limited rebate is factored in. However, dealers still may simply advertise the availability of the matching down-payment program. Also permitted under the Illinois advertising regulations: "$1,000 down + $1,000 matching down payment + $3,000 rebate = $5,000 down payment." However, the ad cannot claim $5,000 in savings because the customer's $1,000 down payment cannot be considered a savings. This article reviews only the impact of the attorney general's advertising regulations on the latest matching down-payment programs. There are other provisions in the regulations with which such ads also must comply but which this article does not address. An up-to-date version of the Illinois Motor Vehicle Advertising Regulations is posted on the Web site of the Chicago offices of the BBB. It appears as part of the BBBCATA Ad Review Program, at cataad.html Under the ad review program, developed in 1996, the BBB reviews local automobile advertising for compliance with the state's regulations. If a noncompliant ad is not revised nor modified, the matter is forwarded to the attorney general's office for review and possible action.