Guidelines for Dealer Pricing and Marketing on CarGurus

Pricing on CarGurus

All prices displayed for vehicles on the CarGurus.com website, mobile and other applications, products, and services (the “Site”) must reflect the total price available to any shopper. The price must include all mandatory dealer-imposed fees and charges required to purchase the vehicle as advertised, except for tax, title, license, registration, and other mandatory government fees.

Prices cannot:

• Be conditioned on a down payment, trade-in, or trade equity
• Apply or incorporate incentives, rebates, or other discounts unless they are automatically available to all shoppers without requiring an application, approval, qualification, or other condition
• Require financing through the dealership, a preferred lender, or another specified financing source
• Require the shopper to use a particular payment method to obtain the advertised price
• Require payment of additional amounts, fees, or charges not already included in the advertised price
• Require the purchase of additional products or services to obtain the advertised price

Any such fee or charge disclosed through CarGurus must be clearly and accurately labeled and must correspond to the actual dealer fee or charge being imposed.

Dealers must not manipulate the CarGurus fee disclosure tools or services, including disabling, mislabeling, or toggling fee entries to obscure mandatory charges, make the advertised price appear lower than the actual purchase price, or obtain a more favorable Deal Rating.

Examples of mandatory dealer fees and charges that must be disclosed include, but are not limited to:

• Documentation fee
• Vehicle reconditioning fee
• Dealer processing fee
• Electronic filing fee
• Market adjustment fee
• Mandatory dealer-installed or pre-installed products or packages, when required to purchase the vehicle as advertised

Dealers may not use fee labels that are misleading, obscure the nature of the charge, describe shopper qualifications or transaction conditions as though they were fees, or otherwise create a misleading impression about the vehicle’s advertised price.

Examples of fee labels or fee entries that do not comply with these guidelines include:

• “John's Dealership Financing Rebate”
• “Down payment required”
• “120” - as the fee name, not the fee amount, or otherwise incomplete or unclear
• “Price Does Not Include Prep Fee 299”

If CarGurus determines that a dealer’s pricing, fee disclosures, or listings do not comply with these guidelines, CarGurus may take action appropriate to the circumstances, including removing or disabling pricing information, fee disclosures, Deal Ratings, individual listings, or inventory. The action may be temporary or permanent and may apply to some or all of the dealer’s listings. CarGurus may consider the nature, severity, persistence, and scope of the issue, including whether the issue is repeated or affects multiple listings. CarGurus may provide notice and an opportunity to correct the issue where practicable, but is not required to do so in every case. CarGurus may consider information from the dealer’s price display on CarGurus, the dealer’s own website, shopper feedback, third-party platforms, and other relevant sources when assessing compliance with these guidelines.

Vehicle listings that do not reflect the total price available to any shopper, including all mandatory dealer-imposed fees and charges required to purchase the vehicle as advertised, are not eligible for Deal Ratings on the Site.

Dealers are solely responsible for ensuring that their pricing, fee disclosures, listings, and related marketing comply with these guidelines and with all federal, state, and local laws, rules, and regulations applicable to such Dealers.

Listing Guidelines

Each vehicle listing must accurately reflect the make, model, year, trim, VIN, options, and other features of the specific vehicle for sale. Intentional misrepresentation or manipulation of any of these characteristics is prohibited.

The listed vehicle must be in the dealer’s possession and available for purchase, and the dealer must have the right and ability to transfer title to the vehicle. Dealers must promptly remove sold vehicles and any vehicles that are otherwise unavailable for immediate sale from the CarGurus platform.

If CarGurus determines that a dealership is posting inaccurate or unavailable listings, CarGurus may remove the affected listings or some or all of that dealership's entire inventory with or without prior notice.

If a dealer listing includes media content, such as images or videos, that content must accurately represent the vehicle being offered for sale. CarGurus may remove images and videos that are inaccurate, misleading, inappropriate, or otherwise unsuitable for the Site.

CarGurus Content

CarGurus may delete, move, condense, or edit any content that CarGurus determines is inaccurate, misleading, inappropriate, or otherwise unsuitable for the Site.

CarGurus may exclude or remove from the Site embedded contact information in images, often known as "Watermarking," if CarGurus determines in its sole discretion that such information is embedded with the intent of circumventing the CarGurus lead routing process.

Deal Rating Badges

CarGurus may permit a dealer to display a CarGurus Deal Rating Badge on the dealer’s website, subject to CarGurus sole discretion and prior approval. A Deal Rating Badge must be requested directly from CarGurus in advance of each time the badge is displayed (i.e., in advance of each time a page that would potentially display a badge is loaded). A dealer cannot use images or links to images of the Deal Rating Badges on the dealer's website except for the ones requested from and permitted by CarGurus. The prices listed in conjunction with a Deal Rating Badge request and display must be in compliance with these guidelines. All Deal Rating Badges permitted for dealer use by CarGurus must be displayed by dealers only in the exact form provided by CarGurus and only as permitted by CarGurus. CarGurus may terminate the Deal Rating Badges Service or may revoke any dealer's right to use the Service or any Deal Rating Badge at any time in its sole discretion.