Cox Automotive's 2025 survey of 2,300 US car buyers traces the path, so the figures describe US shoppers only. The buyer starts with a need and no fixed answer: just 29% were certain which vehicle they wanted, and 71% went in with an open mind. Research comes next, with an average of 4.6 websites visited. Then cost bites: 62% said leasing or owning a car is too costly. Among new-vehicle buyers, 29% considered both leasing and buying. Credit follows, where 48% wanted to apply online but only 33% did. For just over half, the deal is still done in person: 53% completed all steps at the dealership. An agency can reach the first two steps with search and listings. If its adverts at steps three and four quote a payment, a deposit or a rate, rules attach to those words. For a car dealership (a car dealer in the US), that is where an agency does harm or good.
1. How will a lease advert differ from a loan advert?
A buyer weighing a lease against a loan may see both adverts in one evening, and the two can share a monthly figure and little else. In the US, Regulation Z treats the amount of any payment, the number of payments, the amount of any finance charge and the size of any downpayment as triggering terms in a closed-end credit advert, and an advert using one must also state the downpayment, the terms of repayment and the annual percentage rate. A lease advert is different, because Regulation M is triggered by the amount of any payment, or by a statement of any payment made before or at consummation (the signing) or by delivery, including a statement that none is required. Regulation Z requires an advert that states a rate of finance charge to call it an annual percentage rate, using that term. For a lease, Regulation M says a lessor shall not use the term annual percentage rate, annual lease rate or an equivalent term. A lease advert that triggers the rule must also state that the transaction is a lease, the total due at signing or delivery, the scheduled payments, whether a security deposit is required, and a statement about an extra charge at the end of the term.
Ask the agency to write a loan advert and a lease advert for the same car and the same monthly figure, from separate templates, and to explain each difference in wording. If the two versions differ only in the word "lease", the templates are not doing their job. An APR printed on a US lease advert is worth questioning on the spot.
2. Which finance rules will you write to, in which country?
The rule changes with the country, so "the usual small print" will not do. In the UK, FCA rule CONC 3.5.3R asks for a representative example whenever a promotion shows an interest rate or any amount tied to the cost of credit. The example duty falls away where the promotion relates only to credit agreements with an APR of 0%, although FCA guidance counts a reference to 0% credit as indicating a rate of interest.
In the US, ask which federal rule the agency treats as current. An FTC final rule published on 12 February 2026 withdrew the FTC's CARS Rule, which would have required accurate pricing disclosures in dealers' advertising. A Fifth Circuit decision of 27 January 2025 had vacated it. The rule lists only three parts of the FTC's own regulations: 16 CFR 425, 463 and 910. Regulation Z and Regulation M sit in the Consumer Financial Protection Bureau's chapter of title 12. In our reading, the withdrawal therefore did not touch them. An agency that cites CARS as live has not been checking.
3. Where will the rate, deposit and term in each advert come from?
Correct wording can still carry the wrong numbers. In the US, Regulation Z says an advert that states specific credit terms shall state only those terms that actually are or will be arranged or offered by the creditor. In the UK, the FCA's guidance says a representative example is unlikely to be representative if, for example, most customers are likely to borrow a lower amount, or pay higher rates or charges, than the example shows. A headline rate that only a few of your buyers will receive is therefore a weak foundation for an advert.
Each figure should be copied from the lender's current rate sheet or confirmed by your finance manager, and last quarter's advert is not a source. Pick one figure in a live advert the agency runs and ask it to trace that figure back to the sheet it came from, with the date the sheet was refreshed and the name of whoever approved the change. If your lender hands you approved wording that you can use as it stands, a freelancer or your own team may write it as well as an agency can; we think the agency then earns its fee on search, listings and follow-up.
4. What does the monthly headline figure include?
Take a headline such as "£199 a month". In the UK, CAP's advice on motoring finance and leasing gives that example for a business contract plan that also required a £3,000 deposit and an optional £7,000 final payment. The ASA ruled that the ad was likely to mislead readers into thinking only the monthly costs were payable. The advice comes from the CAP Executive, covers non-broadcast advertising and does not bind the ASA. The advice adds that non-optional fees such as the deposit should be in the headline, with the optional final payment stated in a linked footnote or a sub-heading. It applies where the agreement is not an FCA regulated agreement.
Give the agency a sample deal and have it sort every payment into the headline, the footnote or the lender's own document before a word is drafted. A footnote that repairs a misleading headline is a weak fix. Then change the deposit and watch how long it takes for the search advert, the landing page and the listing site to show the same new figure.
5. Who, by name, writes and checks each finance advert?
Ask for three names, not job titles: the person who writes the advert, the person who checks its numbers against the lender's sheet, and the person who can take it down on a Sunday. In the UK, the representative-example rule speaks of the firm communicating or approving the financial promotion, so it matters who in the chain holds that role. The writer and the checker should be different people, and someone should cover each when they are away. Ask whether the writer is an employee or a subcontractor, and whether the person you meet in the pitch will still be on your account in month six. Meet the person who checks the numbers, not only the account manager.
6. What happens when a finance offer changes or ends mid-campaign?
Lenders change rates and withdraw offers while adverts are still running. In the UK, FCA guidance says that where a rate applies for only a limited period, the duration and the rate after that period, if known, should be shown. In the US, Regulation M lets a lease advert state that a specific lease is available only if the lessor usually and customarily leases at those amounts or terms. That gives a dealer a reason to pull a lease advert once the lessor stops offering those terms.
Ask for one past example, with the client's name removed, of a finance advert that had to be pulled: how long it stayed up across search, social, listing sites and email, who pulled it, and what changed afterwards. Agree the time limit for the next one in writing. The same conversation should cover the opposite case, where the adverts run correctly but the finance leads do not arrive, with a review date and the right to stop.
7. How will the adverts show that the dealer is a broker, not a lender?
This applies in the UK. The FCA tells motor dealers applying for authorisation to demonstrate how their communications more generally alert customers to the fact they are dealing with the dealer, not the lender. That is guidance on what the regulator expects to see in an application, last updated on 15 November 2023, not a rule for adverts. Ask to see one finance landing page or email the agency has built where broker status is visible, who approved its wording, and whether the lender signed off any finance figure on it.
8. How will you report finance enquiries, and what counts as one?
Finance behaviour online is uneven. Cox found that 48% of buyers wanted to apply for credit online, but only 33% did, and that 40% wanted to select finance and insurance products online, yet only 16% did. A finance enquiry might therefore be a credit application, a payment-calculator click or a phone call, and a report that lumps them into one number cannot show which advert earned its budget.
Ask for a written definition of a finance enquiry, a separate line for it in the report, and a monthly check of those enquiries against the deals your finance manager signed. Ask whether the report splits loan enquiries from lease enquiries, since the advert rules differ between the two. The attribution post covers the general method. The Social Target's own dealership services are listed at marketing for car dealerships.
What to bring to the agency meeting
- Your lender's approved finance wording, if you have any.
- A request for a loan advert and a lease advert for the same car, side by side.
- One live figure to trace back to its rate sheet.
- Three names: writer, checker, and whoever can pull an advert on a Sunday.
- The agency's written definition of a finance enquiry.
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↳ Frequently asked
01Does a 0% APR offer need a representative example in a UK advert?
Not under CONC 3.5.3R, which lifts the representative example duty where a promotion relates only to credit agreements with an APR of 0%. That exception covers the example only, and FCA guidance still counts a reference to 0% credit as indicating a rate of interest, so the lender should approve the final wording.
02Can a US lease advert call its interest figure an APR?
No. Regulation M says a lessor shall not use the term annual percentage rate, annual lease rate or an equivalent term when it gives a percentage rate in a lease advert. Regulation Z asks for that exact term in credit adverts, so a dealership running both needs separate wording for each.
03If my lender supplies approved finance wording, what is left for a dealership's agency to do?
Less writing, but not less work. Someone still has to keep the approved figures identical across search adverts, landing pages and listing sites after every rate change, pull adverts when the lender withdraws an offer, and report loan and lease enquiries separately against the deals your finance manager signs. If that workload is small at your dealership, a freelancer or your own team may cover it for less.
04Must a UK headline of £199 a month show the deposit?
CAP's advice says so for a car lease that is not an FCA regulated agreement. It says non-optional payments such as the deposit belong in the headline, and an optional final payment can sit in a linked footnote. The advice comes from the CAP Executive and does not bind the ASA.