Four things, in money you actually control.

01

Used and aged-unit merchandising

Against the live inventory feed, VIN by VIN, triaged by days on lot and by turn. Not a model-line template that ran last month with the year changed, and not a spend allocation that has been the same since the account was opened.

Aged units are where the money is on the used side, and they are the units a template never reaches, because a template advertises what is easy to photograph.

Measured on: units moved off aged inventory, cost per sold unit, days to turn.
Co-op: none. Full vendor freedom.

02

Owner base, equity and service-to-sales

The customers already in your DMS: equity position, lease maturity, and the service drive treated as a sales channel rather than as a cost centre. This is the cheapest inventory of intent any store owns and the one most consistently left alone.

It runs on first-party audiences built from your own CRM, which matters more than it used to — platform targeting has been narrowing for years and the data you own is the part nobody can take away.

Measured on: appointments set and shown from the owner base, units from service.
Co-op: none.

03

Prequal to desk

The soft-pull tool is not the product. Everybody has one and they all work about the same. The product is what happens after the pull: which tier the customer lands in, which lender that routes to, how the deal is structured before they walk in, and what the BDC actually says when the file comes back.

That is F&I work, not marketing work, and it is the reason this exists as a service at all. Full Desk only.

Measured on: prequal submissions matched back to sold units, with F&I gross and product penetration per cohort.
Before anything runs: FCRA permissible purpose confirmed in writing, and a Safeguards Rule service-provider agreement executed — the moment I can see pull output, I am a service provider under your obligations, and that gets papered first.

04

Co-op, MAP and the New Jersey ad rules

Claim files assembled to the brand’s format and handed to you inside the submission window, rather than reconstructed in a panic the week it closes. Price-bearing creative checked against the brand floor and against 26A before it ships.

And the ad side of your record retention, held and retrievable.

26A.10 requires you to keep the advertisements and the executed contracts for 180 days for Division inspection. I hold the ad side and the inventory snapshot that justified each price. The contract side lives in your DMS and stays yours — anyone selling you “180-day compliance” as a single product is selling you half the file.

Meta’s Financial Products and Services category

Creative promoting credit, financing, auto loans or lease programs has to run in the Financial Products and Services Special Ad Category — the one that replaced the old Credit category for US advertisers in January 2025. In it you lose ZIP targeting, location exclusions, age below 18–65+, gender targeting, platform lookalikes and Advantage targeting.

Note how that actually works, because it is usually explained backwards. Meta does not classify your campaign for you. You declare it, and Meta enforces against undeclared ads when it finds them. So there are two different situations and they need different fixes: if your finance creative was declared, your targeting is not the targeting you set; if it was never declared, the targeting is fine and what you have instead is a policy violation waiting to be caught.

Which one you are in takes ninety seconds to check in Ads Manager, and it is the first thing I look at. First-party audiences from your own CRM and pixel work in either case — a large part of why the owner base is where I point that budget.

The federal CARS Rule is gone. 26A is not.

The FTC’s CARS Rule was vacated by the Fifth Circuit in January 2025 for skipping the advance notice step, the FTC did not appeal, and it was formally withdrawn from the Code of Federal Regulations effective February 2026.

Every GM in New Jersey heard about that rule and a good number still think they are complying with it. The rule that actually governs your advertising here never went anywhere, is a state regulation, and is enforced by the Division of Consumer Affairs.

If a vendor is still selling you CARS Rule compliance in 2026, that tells you what their compliance product is worth.

Who counts as the advertiser — including me

Under 26A.3 an agency is deemed an advertiser when its staff prepares and places an advertisement. Billing media direct to your accounts is an argument that the placing half stays with you. It is an argument, not a shield. “Places” is not defined in the rule, and on any program where I am building and running campaigns I should expect to be treated as an advertiser alongside you.

I would rather say that than imply I have engineered my way out of it. It is also why the compliance work is not a favour: the exposure is partly mine, so a non-compliant ad going live is my problem too, and that alignment is worth more to you than any clause.

Nothing here is legal advice. Have your attorney read 26A.3 and tell you what they think — including about my position, not just yours.

No payment or lease advertising

I do not build creative that states a monthly payment, a down payment, a term or a rate. Those are triggering terms under Regulation Z and Regulation M and they drag a full disclosure set behind them.

If you want payment creative, your OEM-approved agency already produces it inside the co-op program and it costs you nothing extra. That is genuinely the right home for it.

What I build instead: availability-led, trade-led and inventory-led offers, which are also the only genre available on a brand with an MSRP advertising floor.