The FTC Buyers Guide: What Every Carolina Used Car Dealer Must Put on the Window

You put a car on the front line. Sparkling clean, priced right, keys in the cup holder. But is the Buyers Guide on it?

If you sell used cars in North Carolina or South Carolina, that little window form isn't optional paperwork. It's a federal requirement from the FTC's Used Car Rule (16 CFR Part 455), and it applies to dealers in all 50 states. Let's walk through it, the plain-English CDT way!

Who Has to Use It?

The Rule defines a dealer as any person or business that sells or offers for sale a used vehicle after selling or offering five or more used vehicles in the previous twelve months. Banks and financial institutions, businesses selling to their own employees, and lessors selling a leased vehicle to the lessee (or the lessee's employee) are excluded.

A used vehicle is one driven more than the limited use needed to move or road test a new vehicle before delivery. Vehicles sold only for scrap or parts (title surrendered, salvage certificate issued) are not covered. The Rule also covers only certain vehicles: motorized vehicles other than motorcycles, with a GVWR under 8,500 lbs., a curb weight under 6,000 lbs., and a frontal area under 46 sq. ft.

Short version? If you're a regular used car dealer selling cars and light trucks to consumers, plan on using it for every one!

Before You Offer It for Sale

Before you offer a used vehicle for sale to a consumer, you must prepare, fill in, and display the Buyers Guide on that vehicle. The rules for the display are specific:

It must be prominent and conspicuous, in any location on the vehicle, and readable from both sides.
You may take it off for a test drive, but it goes right back on when the drive is over.
The wording, capitalization, and punctuation must be exactly what the Rule requires.
It must be printed in 100% black ink on white stock at least 11 inches high by 7¼ inches wide.

Filling It Out

1. Warranty status. This is the big one. Pick the one that matches the deal:

As Is – No Dealer Warranty: you offer the vehicle without any implied warranty.
Implied Warranties Only: the dealer makes no promise to fix things, but state-law implied warranties may still give the buyer rights.
Full or Limited Warranty: you describe the terms right on the form.

Heads up! If your state law limits or prohibits "as is" sales, state law overrides the federal rule, and you can't use "As Is." In those states the form uses the Implied Warranties Only language instead. Not sure what your state allows? Ask! We cover this in class.

2. If you offer a warranty, the form must say whether it's Full or Limited, which specific systems are covered (you can't just write "drive train" or "power train"; list them, like "engine, transmission, differential"), how long it lasts (for example, "30 days or 1,000 miles, whichever occurs first"), and what percentage of repair cost you pay.

3. Service contracts. If you make a service contract available at an extra charge, add the Service Contract disclosure and check that box. (Service contracts that are "the business of insurance" regulated under state law are the exception.)

4. Vehicle and dealer info. Fill in the make, model, model year, and VIN. Add your dealership's name and address, plus the name and phone number of the person to contact with complaints after the sale. You can add an optional buyer signature line, but if you do, it must come with the statement "I hereby acknowledge receipt of the Buyers Guide at the closing of this sale."

The Part Dealers Forget: The Final Form Is Part of the Contract!

When the deal is done, give the buyer the window form, or a copy that accurately reflects every disclosure and the warranty terms you agreed on. If you negotiated a change (say, you added a 30-day warranty), mark it on the form.

And here's the kicker: the information on the final Buyers Guide is incorporated into the sales contract, and it overrides any contrary provision in the contract. Each consumer contract must conspicuously say so, using this language:

The information you see on the window form for this vehicle is part of this contract. Information on the window form overrides any contrary provisions in the contract of sale.

Also, you may not make statements, oral or written, that contradict the Buyers Guide. Telling a customer "don't worry, I'll take care of it" when the form says "As Is"? That's exactly what the Rule is aimed at. Negotiate warranty terms if you like, but get the final terms on the form and in the contract.

Selling in Spanish?

If you conduct the sale in Spanish, the window form and the contract disclosure must be in Spanish too. The Rule provides Spanish versions of the form. You can display both an English form and a Spanish translation on the vehicle.

Quick Dealer Checklist

☐ Every consumer-sale used vehicle has a Buyers Guide displayed before you offer it
☐ The "As Is" / Implied Warranties Only / Warranty box matches the deal you actually make
☐ Covered systems, duration, and percentage are spelled out on any warranty
☐ VIN, make, model, year, and complaint contact filled in
☐ Changes after negotiation marked on the form, and the buyer gets a copy
☐ The contract includes the "window form is part of this contract" language
☐ Spanish sale? Spanish form and contract disclosure

Learn It Once, Sell with Confidence

The Buyers Guide is one of those things that seems simple until a deal goes sideways. That's why we cover the federal rules (FTC and more!) alongside the state requirements in our classes.

Licensed NC dealer renewing? Our 2026 Online NC Dealer CE course is built for licensed NC dealers renewing, not for getting a new license. Getting licensed in NC? Join us for the NC 12-hour Pre-License class in Greensboro, Nov. 19-20. Heading toward an SC license? Check out the SC 8-hour Pre-License class in Columbia on Nov. 24.

Questions? Ask us! We offer ongoing support after you take our class, at no additional cost!