OMVIC All-In Price Advertising and Standards Flashcards

A dealer advertises a certified pre-owned vehicle at $24,499 'all-in (excluding HST and licensing).' At the point of sale, the customer is charged a $349 PPSA registration fee and a $199 VIN verification fee, both described as 'third-party processing charges.' What is the compliance issue?

Answer: Both fees violate the all-in price rule because they are dealer-imposed charges that must be included in the advertised price

Under OMVIC's all-in price rule, every fee a dealer charges — regardless of how it is labelled — must be included in the advertised price. PPSA registration fees and VIN verification fees are dealer-imposed charges, not government licensing fees. Calling them 'third-party' or 'processing' charges does not exempt them. Only HST and provincial licensing/registration fees paid directly to the government are excluded.

A dealer pre-installs window tinting ($450), a remote starter ($650), and paint protection film ($800) on every vehicle before advertising it. The ads list the base vehicle price and note 'optional accessories available.' A buyer later discovers all three products are already physically on the car. Which statement best reflects OMVIC's all-in price requirements?

Answer: All three accessories must be included in the all-in price because they are present on the vehicle as advertised and as delivered

The all-in price must reflect the total amount a consumer would pay for the vehicle in the condition it is offered for sale. If accessories are physically installed on a vehicle before it is advertised, their cost must be included in the all-in price — regardless of whether removal is theoretically possible. Advertising the base price while accessories are already on the car is a misrepresentation of the actual selling price.

A dealer's online listing shows a new SUV at $38,999 'all-in' with a footnote that reads: '*Price requires a minimum $5,000 trade-in allowance.' A customer without a trade-in asks to purchase the vehicle at that price and is refused. What is the primary compliance issue under OMVIC standards?

Answer: Advertising a price that is conditional on a trade-in as the primary displayed price violates OMVIC's all-in advertising rules because not all buyers can achieve that price

An all-in price must represent what any member of the public can pay for the vehicle, without conditions. Making the advertised price contingent on providing a trade-in creates a deceptive price — most buyers will not qualify for it. OMVIC's standards require that the advertised price be achievable by any consumer walking through the door; a trade-in condition fundamentally undermines this requirement and constitutes misleading advertising.

A dealer charges every customer a $25 'Eco Disposal Fee' covering battery and fluid recycling — a program organized by the dealer, not mandated by provincial legislation. The dealer argues this fee is analogous to a government environmental levy and excludes it from the all-in price. Under OMVIC's rules, is the dealer correct?

Answer: No — only fees mandated and set by provincial or federal legislation may be excluded; a dealer-created eco fee must be included in the all-in price

The all-in price exemptions are narrow: only HST and government-set licensing/registration fees may be excluded. A fee that a dealer collects, controls, and has chosen to implement — even if framed as environmental — is a dealer-imposed charge. It must be included in the all-in price. The label 'eco' or 'environmental' has no legal exemption status under OMVIC's advertising standards.

A dealership's radio advertisement says: 'Drive home this weekend's featured pickup for only $599 a month!' The all-in price is mentioned in a rapid, difficult-to-follow spoken disclaimer at the end. Which OMVIC advertising principle does this most directly violate?

Answer: The all-in price must be communicated with equal prominence to any advertised payment amount — including comparable pacing or audibility in audio-format ads

OMVIC's all-in price rule requires that the all-in price be displayed or communicated at least as prominently as any other price representation — including monthly payments. In audio formats, 'prominence' means the all-in price must be spoken clearly and at a similar pace, not buried in a rushed disclaimer. Leading with a payment figure while hiding the all-in price in an unintelligible disclaimer is a form of misleading price advertising.

A manufacturer offers a $2,500 'loyalty rebate' exclusively to customers who previously owned the same brand. Dealer A advertises the vehicle at $33,200 all-in, incorporating the loyalty rebate. Dealer B advertises the same vehicle at $35,700 all-in (no rebate) and separately highlights '$2,500 loyalty bonus for returning owners!' Under OMVIC's all-in price standards, which assessment is most accurate?

Answer: Dealer A is potentially non-compliant because the all-in price includes a rebate not available to all buyers, which misrepresents the price a general consumer would pay

The all-in price must reflect what any member of the public — not just a qualifying subset — would pay for the vehicle. A loyalty rebate is conditional on prior brand ownership, meaning most consumers cannot achieve the $33,200 price. Incorporating a restricted, conditional rebate into the headline all-in price misrepresents the real cost to the general buying public. Dealer B's approach of showing the unconditional all-in price and separately advertising the rebate for eligible buyers is the more defensible method under OMVIC standards.