FTC Approves Final Consent Order in Cowboy Toyota Deceptive Advertising Case

Following a public comment period, the Federal Trade Commission has approved a final consent order settling deceptive advertising charges against Cowboy AG, LLC, a Dallas, Texas, company doing business as Cowboy Toyota and Cowboy Scion (Cowboy Toyota).

According to the FTC’s December 2017 complaint, in full-page Spanish-language newspaper ads, Cowboy Toyota misrepresented the cost of purchasing or leasing cars, qualifications or restrictions for financing or leasing cars, and the availability of cars, in violation of the FTC Act. The dealership also failed to disclose credit or lease terms required under the Truth in Lending Act (TILA) or the Consumer Leasing Act (CLA) when they touted certain “triggering” terms of the credit or lease, such as the monthly payment. The complaint also alleged that favorable terms were prominently stated in Spanish in the ads, with material limitations to those terms provided only in fine-print English at the bottom.

The final order settling the FTC’s charges prohibits Cowboy Toyota from misrepresenting the cost of financing, buying, or leasing a vehicle. The order also requires the dealership to accurately represent any qualifications or restrictions on a consumer’s ability to obtain offered financing or lease terms, including restrictions based on their credit history.

Next, the order prohibits Cowboy Toyota from misrepresenting the number of vehicles, makes, or models that are available for purchase or lease. The order requires Cowboy Toyota to clearly and conspicuously disclose all financing and lease terms in its ads, as well as all related qualifications or restrictions. Finally, if Cowboy Toyota makes a representation in one language, it must state clearly and conspicuously any material limitations in the same language.

The Commission vote approving the final consent order was 2-0. (The staff contact is James R. Golder, FTC Southwest Region, 214-979-9376)

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