What's Actually in a Well-Disclosed F&I Menu? A Compliance-First Breakdown
Written by the Vision Management Group team · Reviewed by Julie Barton, National Training Director Published September 2, 2026
A well-disclosed F&I menu separates the vehicle's price from every optional product, states each product's price and term individually, and makes clear the customer can decline any or all of them without affecting financing approval. Vision Management Group builds every F&I menu process (including its own 7-Minute Menu) around that standard.
Here's what actually has to be on the menu, why it matters more in 2026 than it used to, and how to check your own store's menu against it.
What Makes an F&I Menu "Well-Disclosed"?
At minimum, a well-disclosed menu includes:
Itemized pricing. Every product (VSC, GAP, tire and wheel, appearance protection) priced individually. Not bundled into a single monthly payment figure the customer can't unwind.
Explicit "optional" labeling. The menu states, in plain language, that each product is optional and the deal does not require it.
Term and coverage detail. Length of coverage, mileage limits, and what's actually included — not just a product name.
Total amount financed shown separately from vehicle price. The customer can see what they're financing for the vehicle versus what they're financing for add-ons.
A record of individual acceptance or decline. Initials or a signature confirming each product was offered and the customer's choice, not a blanket signature at the bottom of the page.
No product framed as required for approval or delivery. If a product is presented as mandatory when it isn't, that's the menu failing on disclosure regardless of how the pricing is formatted.
Why This Matters More in 2026
For a while, the industry was bracing for a single federal standard here. That's not where things landed.
The FTC's CARS Rule, which would have set a uniform add-on disclosure requirement nationally, was vacated by the Fifth Circuit Court of Appeals in January 2025, and the FTC formally withdrew it via a February 2026 Federal Register notice rather than appeal. There is currently no single federal "menu disclosure law."
That doesn't mean the F&I office is unregulated. Two things still apply:
Regulation Z (Truth in Lending Act) still governs disclosure of the finance charge and APR whenever a menu product gets rolled into the amount financed. If a product's cost changes what the customer is actually financing, that has to show up accurately in the federal disclosures regardless of menu format.
The FTC still enforces under its general unfair-and-deceptive-practices authority (Section 5), rule or no rule. In April 2026, the FTC and Maryland's Attorney General secured refunds and penalties against Lindsay Auto Group for deceptive pricing and undisclosed add-ons — a similar case against Asbury Automotive shows the agency is still active here even without CARS in effect.
On top of that, states are filling the gap individually rather than waiting on Washington. Massachusetts's Junk Fee Rule, issued by the state Attorney General, took effect in September 2025 and requires all-in pricing. California's SB 766 (the state's own Combating Auto Retail Scams Act) was signed into law in October 2025 and takes effect October 1, 2026; it bars charging for add-ons that provide no consumer benefit and requires written, clear, and conspicuous disclosure that any add-on is optional. More states are expected to follow the same pattern.
Practical takeaway: don't wait for a federal rule that isn't coming back. Build the menu to the itemized, opt-in, plainly-worded standard regardless of which specific law is on the books in your state this year — check your own state's current requirements, since they vary and are changing.
What Enforcement Actually Looks Like
Two active cases show what "undisclosed add-on" enforcement means in practice, not just in the abstract.
In the Lindsay Auto Group settlement, the FTC and Maryland's Attorney General alleged the dealer group charged consumers for products like service plans, tire-and-rim protection, and GAP that "consumers did not want or agree to buy," often adding hundreds or thousands of dollars to the deal. More than $75 million in charges from a five-year window may qualify for refunds, and Lindsay is paying a $3.1 million civil penalty to Maryland. The pattern the FTC describes isn't a pricing dispute; it's products showing up on the contract that the customer never agreed to.
The Asbury Automotive case (still pending as of this writing) alleges a specific mechanic the FTC calls "payment packing": convincing a customer to agree to a monthly payment larger than the car itself requires, then filling that gap with add-on products the customer didn't ask for. That's the exact failure mode the "explicit optional labeling" and "total amount financed shown separately" components above are built to prevent — when the payment is presented as one number before the product list is itemized, packing is structurally easy to do without anyone having to lie outright.
Neither case is about pricing products too high. Both are about what the customer was told, and when, relative to what ended up on the contract. That's the disclosure problem this post is about, playing out at enforcement scale.
How VMG's 7-Minute Menu Builds This In
VMG's 7-Minute Menu Process sequences the conversation so disclosure happens naturally instead of getting rushed at the end. Loan context and ownership-cost reasoning come before any product is presented, so the customer understands what a product actually covers before they're asked to accept or decline it — rather than seeing five line items stacked onto a payment they've already fixed in their head.
That sequencing is a presentation discipline, not a substitute for your dealership's own compliance sign-off. Every store's specific disclosure language should be reviewed by dealer counsel before it goes in front of a customer.
Well-Disclosed vs. Poorly-Disclosed: What the Difference Looks Like on Paper
The same three products, presented two different ways:
Poorly-disclosed menu | Well-disclosed menu | |
Pricing | One monthly payment figure, products folded in | Each product priced on its own line, separate from vehicle price |
Optional language | Products presented as part of "the deal" | Each product explicitly labeled optional, in plain language |
Amount financed | Shown as a single blended number | Vehicle amount and add-on amount shown separately |
Customer acknowledgment | One signature at the bottom of the page | Individual initials or signature per product, accept or decline |
Sequencing | Products introduced after a payment number is already on the table | Loan context and ownership-cost reasoning precede any product presentation |
What it produces | Customer sees five items and negotiates down to hit a number | Customer decides on each product based on what it actually covers |
The left column isn't a hypothetical worst case. It's the structural setup the FTC describes in the Lindsay and Asbury complaints above: a payment number presented first, products attached after, and disclosure happening (if at all) as a formality rather than as informed consent. Nothing in the left column requires an F&I manager to lie. Sequencing and formatting alone determine which column a given deal falls into.
A Quick Self-Check: Is Your F&I Menu Well-Disclosed?
Pull up your current menu and check:
Is every product priced on its own line, separate from the vehicle price?
Does the menu say, in words the customer will actually read, that each product is optional?
Can a customer see the total amount financed broken out from the vehicle price?
Is there a signature or initial next to each individual product, not one signature covering the whole page?
Would a customer be able to tell, just from looking at the menu, that declining a product doesn't kill the deal?
If any answer is no, that's a specific, fixable gap — not a reason to redo the whole process.
FAQ
What does "well-disclosed" mean on an F&I menu?
It means every optional product is itemized with its own price and term, explicitly labeled optional, and confirmed individually by the customer — as opposed to bundled pricing or a single blanket signature covering multiple products.
Is there a federal law that requires F&I menu disclosure?
Not currently. The FTC's proposed CARS Rule, which would have set a national standard, was vacated by the Fifth Circuit in January 2025 and formally withdrawn in February 2026. Regulation Z still governs financed amounts and APR disclosure, and the FTC still enforces general unfair-and-deceptive-practices rules, but there's no single federal menu-disclosure statute right now. States are increasingly setting their own rules instead.
What happens if a dealer doesn't clearly disclose optional products?
It creates exposure on two fronts: regulatory (state attorneys general and the FTC have both pursued "payment packing" and undisclosed add-on cases) and operational (unclear disclosure is a leading driver of F&I-related CSI complaints and chargebacks).
Does Vision Management Group's menu process meet these standards?
VMG's 7-Minute Menu Process is built around itemized pricing, explicit optional labeling, and individual product confirmation. Every dealership's exact menu language should still be signed off by its own compliance counsel, since requirements vary by state.
Where can I find my state's specific F&I disclosure requirements?
Check with your state's Attorney General's office or Department of Motor Vehicles, since these rules are changing state by state — Massachusetts and California are the most recent examples. Your dealer compliance counsel is the right resource for a definitive answer for your store.
What to Remember About Well-Disclosed F&I Menus
A well-disclosed F&I menu isn't complicated: itemized pricing, explicit optional labeling, and individual product confirmation. What's changed is that no single federal rule enforces that standard anymore — it's state by state, which makes getting the fundamentals right on your own menu more important, not less. If you want a second set of eyes on where your current menu stands, VMG's free Dealer Health Check-Up includes a review of F&I process and disclosure practices.
