The Ad File

Ten business days. One rooftop. Written down.

Not a capabilities deck and not a proposal with an audit stapled to the front. A written document about your store, with the specific rule quoted beside each observation, produced by somebody who has had to defend an advertised price to a customer and a lender in the same afternoon.

$2,450

One rooftop, one time. Credited in full against your first month if you go on to a program, so it costs nothing if I am any good. You keep the document whichever way it goes, and there is no version of this where it is withheld pending a signature.

Book it Read a specimen first

What it checks, and what each part needs

Two thirds of this needs nothing from you but your permission to look.

Your advertising is public. So the compliance read, the MAP exposure and the offer-structure critique get written whether or not anybody grants me anything — which matters, because at a lot of stores the incumbent agency owns the ad account and decides who sees inside it.

Pass 01 · needs nothing — your ads are public

Every live advertisement, against the rule it sits under

Your VDPs, feeds, search ads, display and social placements read against the New Jersey advertising regulations. Each observation states what is live, quotes the rule text, and stops there.

Chiefly 26A.5 (all-in price, doc fee inside, ten-point footnotes, last eight VIN digits) and 26A.8 (credit terms adjacent to the vehicle, never in a caption). Also 26A.6, the toll-free number rule — 9am to 9pm Monday to Saturday, maintained 48 hours past the last day of the ad, answering seventeen enumerated items.

Pass 02 · needs one document from you

MAP exposure

Your brand’s current advertising floor, read off your own dealer-agreement addenda, against every asset priced underneath it.

The addenda come from you, not your agency — which is why this pass survives an incumbent who will not cooperate. Floors are revised annually, so this is read fresh rather than off what the floor was two years ago.

Pass 03 · needs nothing

Offer structure

What your advertising actually says, against three tests: can a manager desk a deal from it, does it clear the brand floor, and does it satisfy 26A. Most non-compliant advertising is not a compliance decision, it is an offer nobody structured.

This pass is also where the largest reallocation usually shows up, and it needs no account data to find — what you are advertising is visible from the street.

Pass 04 · needs your co-op statements

Two quarters of co-op, in dollars

What you claimed. What was denied, and on what ground. And the number nobody counts: what was never submitted and expired.

Your statements, from your own files. Five of the six common denial grounds are procedural — wrong entity name, no service period, deliverables not itemised, creative undated — and those come back. The sixth is that you were not eligible, and the only cure for that is finding out before you spend.

Pass 05 · needs a read-only seat on the ad accounts

Forensics on the incumbent — and what happens if you cannot grant it

Change history with dates. Age of the negative-keyword list. Brand versus non-brand spend split. Tracking pixels still firing for agencies you fired. How many vendors are claiming credit for the same sale in your CRM. The most common single finding, by a distance, is an account nobody has meaningfully touched in years, spending most of its budget buying your own store name back from you.

This is the one pass that can be blocked, and often it is not you blocking it. At a great many stores the ad account sits inside the agency’s own manager account, and the grant is theirs to refuse. If that happens, two things follow. The first is that you get the other four passes in full, on the same timeline, at the same price. The second is that who owns your advertising account becomes the first line of the document, because a vendor who can lock you out of the history of your own spend has already answered the question you hired me to ask.

Read-only. I never need edit rights during an Ad File, and I will not ask for them.

Specimen

What one page of it looks like.

This is a constructed example, not a real store. The regulations quoted are real and quoted accurately. The dealership, the stock numbers and the figures are invented, because a genuine finding names a real store’s advertisement and publishing that would hand a complaint to whoever wanted to file one.

And a word on what this document is not. I am not a lawyer and the Ad File is not a legal opinion. Every finding states what is live, quotes the published rule text, and stops — it does not conclude that you are in violation of anything. That determination is your attorney’s, and every finding is written so it can be handed to them without translation.

Second Pencil · NJ Ad File

Rooftop 01 — [FRANCHISED STORE, MIDDLESEX COUNTY]

Prepared: Day 10
Placements read: 214
Observations: 11
Account access: Granted

Section 1 — Advertising observations, against published rule text

F-01 N.J.A.C. 13:45A-26A.5(a) For counsel · priority

Doc fee shown outside the advertised price on 186 of 214 vehicle detail pages.

Observed, 14 March, 09:20: price displayed as $24,995, with “plus $999 documentary service fee, tax, tags” in the disclosure block beneath. Screenshots and the full crawl are at Appendix A.

The rule text reads: the advertised price must include all costs to be paid by a consumer except for licensing costs, registration fees and taxes. A documentary service fee is not named among those three exceptions.

If you decide to change it: reprice the feed to an all-in figure. One template change, propagates to all 186.

F-02 N.J.A.C. 13:45A-26A.8 For counsel · priority

Credit terms appear in the caption on four paid social placements.

Observed, 14 March: the term and the rate appear in the caption text beneath the creative, not within it.

The rule text reads: credit terms must appear adjacent to the description of the advertised motor vehicle and not in a footnote or a headline.

If you decide to change it: terms move into the creative beside the vehicle, or the terms come out and the placement runs without them.

F-03 N.J.A.C. 13:45A-26A.5 For counsel

Disclosure footnote measured at 8 point on two print insertions.

The rule text reads: footnote type shall be at least ten point. Measured at 8pt on both; the measurement method is at Appendix B.

If you decide to change it: typographic, costs nothing, closes two observations.

Section 2 — MAP exposure (from your dealer-agreement addenda)

M-01 Brand advertising policy, addendum dated 1 Feb Allowance at risk

Nine units advertised below the floor stated in your current addendum.

Not a regulatory matter and no agency enforces it. Your manufacturer does, by withholding the marketing allowance, and the policy was revised this year.

Alternative: the nine move to availability-led and trade-led creative, which is the genre that works on a floor-restricted brand anyway.

Section 3 — Co-op, last two quarters (from your statements)

Constructed figures. Yours are read off your own submissions.
Status	Amount	Ground
Claimed and paid	$18,400	—
Claimed, denied	$6,220	Invoices not itemised; service period absent on three
Never submitted	$11,750	Window closed. Nobody was tracking it.
Procedural, recoverable forward	$17,970	These come back once the invoice format changes.

Section 4 — Account state (read-only seat, granted 3 March)

Last substantive change to the search account: 31 months ago (change history export, Appendix C).
Negative keyword list: 41 entries, most recent added 3 years ago.
Brand vs non-brand split: 71% of spend on queries containing the store name.
Tracking pixels firing: 5 total, 2 belonging to domains not associated with any current vendor.
Duplicate attribution: 4 vendor tags claiming the same 62 sales in the CRM export.

Stated as account state, with the exports attached. This section does not characterise anyone’s competence, and it does not recommend that you terminate anybody.

Book it

If the answer is that your incumbent is doing a good job, that is what it will say.

You will have paid $2,450 for the most useful second opinion available in this market, and I will tell you so in writing. That outcome happens, and it is the reason the rest of the findings are worth believing.

Book the Ad File