| U.S. dealer market scale remains competitive | 8.1M light vehicles sold by retailers in H1 2025; 16,972 franchised dealerships | NADA market beat, 2025-07-15 | Set pilot targets as local share capture and mix quality improvements, not demand creation alone. | NADA [S1] |
| Fully online purchase is still minority behavior | 57% of buyers started at dealerships; 7% started and finished online; 63% want smoother all-digital process | Cox Automotive, 2025-05-30 | Keep tool outputs tied to phone/chat/showroom transitions. Pure digital-only assumptions are risky. | Cox Automotive [S2] |
| Borrowing costs are materially elevated | 48-month new-car loan rate at commercial banks: 7.53% (latest Nov 2025 value) | FRED / FRB data updated 2025-12-05 | Finance-led ad claims need stricter qualification and disclosure QA before scale. | FRED / FRB [S3] |
| Credit stress is visible in auto portfolios | Auto-loan balance reached $1.667T; serious delinquency transition at 2.95% in Q4 2025 | NY Fed report, 2026-02-10 | Aggressive volume pushes can degrade lead quality unless credit-band routing is defined. | NY Fed [S4] |
| Affordability pressure is visible in loan structure and early delinquency | Q3 2025 average payments: $748 new / $532 used; used APR 11.40%; 73-84 month terms nearly 30% of new loans and 27.22% of used loans; 30-day delinquency 1.99% | Experian State of the Automotive Finance Market, 2025-11-19 | Use credit-tier routing and lender-fit rules in pilot design; volume-only goals can increase low-quality lead flow. | Experian [S10] |
| Dealer cybersecurity obligations are explicit and operational | FTC notes most automobile dealers are covered by the Safeguards Rule and should assess attack scenarios common in auto retail; notification is required when 500+ consumers are impacted by unencrypted data breaches | FTC business guidance updated 2025-11 | Lead-export and finance-workflow tooling should include access controls, incident ownership, and breach-response runbooks before scale. | FTC Safeguards [S11] |
| Review manipulation now carries direct federal-rule exposure | FTC Rule on Fake Reviews and Testimonials has been in effect since 2024-10-21 and allows civil penalties for knowing violations | FTC rule page checked 2026-02-18 | Reputation growth programs need auditable review-source governance; avoid incentivized or fabricated review tactics. | FTC Reviews Rule [S12] |
| Payment-led advertising has trigger-term disclosure requirements | Reg Z §1026.24 requires additional disclosures when ads include payment amounts, down payment, or financing terms | eCFR current through 2026-02-13 | Treat financing creatives as compliance-gated assets; launch only after disclosure checklist sign-off. | CFPB Reg Z [S13] |
| Google vehicle ads have hard setup boundaries | Vehicle ads are scoped to specific countries and require policy-compliant account/feed architecture | Google Ads docs checked 2026-02-18 | Multi-rooftop groups should validate account, feed, and store-code prerequisites before media scaling. | Google Ads docs [S5-S7] |
| Monroe-local paid benchmark remains unavailable | No reliable public Monroe-county CPL and lead-to-sale split by inventory category | Research audit 2026-02-18 | Treat local benchmark assumption as pending confirmation and replace with first-party exports. | Pending confirmation [U1] |