On June 10, the Federal Trade Commission (“FTC”) announced that it entered into a consent order with an Arkansas car dealer over charges that the car dealer failed to display a “Buyers Guide” on used cars offered for sale. In connection with the settlement, the car dealer agreed to pay a $90,000 civil penalty to the FTC. In its complaint, the FTC alleged that by failing to display the Buyers’ Guide which is designed to provide consumers with warranty and other important information on used cars, the car dealer violated the FTC’s Used Car Rule, and therefore violated the Federal Trade Commission Act (“FTC Act”). As part of the consent order, the car dealer is prohibited from (i) misrepresenting or failing to disclose any material fact including those about the mechanical condition of the vehicle and the nature of the warranty offered in connection with the sale of the vehicle; (ii) failing to display the Buyers’ Guide before offering a vehicle for sale and failing to provide the buyer with a properly completed Buyers Guide; and (iii) failing to disclose that the Buyers’ Guide is part of the contact for the vehicle. The consent order also imposes compliance reporting and monitoring, and recordkeeping requirements on the car dealer that extend for as long as ten years after the date of the consent order.