What does the FTC's fake-reviews rule mean for a dealership's reputation and social media vendor?

What the rule prohibits

Per the FTC's own final rule (16 CFR Part 465): fabricated reviews, buying positive or negative reviews, an employee or manager posting a review of their own store without disclosing that connection, suppressing genuine negative reviews (including through a form that routes complaints privately while pushing only satisfied customers to post publicly), and purchasing fake followers, views or other indicators of social influence.

Where dealership practice runs into it

A common, older reputation tactic is a feedback form that funnels a negative response to a private email and a positive one straight to a public review site: the rule's review-suppression provisions were written with exactly this two-path pattern in mind. A sales manager or F&I manager posting their own glowing review of the store they work at is an insider review, not independent testimony.

What to verify with a reputation or social-media vendor

Whether its review-request workflow routes every customer the same way regardless of expected sentiment; how it discloses staff or incentivized reviews if it collects any; and whether any social-proof metrics it reports or displays are organic rather than purchased.

A practical review-request process

Send the same review request to every customer in the same way, regardless of how the visit went, and give customers a plain route to leave feedback on a public site. Do not offer rewards conditioned on positive wording.

If staff or relatives post, follow the disclosure requirements. Keep a record of how requests are sent and reviewed, and ask your vendor to describe its workflow in writing.

Internal steps to take now

Review how your store asks for reviews, who reads the responses and whether employees or relatives post about the store. Document the policy, train staff and ask your vendor to describe its process in writing.

Review the policy each year and after any change of vendor. Involve counsel for questions about your specific practices.