Pricing Compliance Review

Subject: Internal and External Pricing Standards and Regulatory Compliance

1. Purpose and Scope

The purpose of this Pricing Compliance Review is to provide a clear, plain-language set of pricing compliance standards for Money Saver AppliancesLLC (“the Company”). It is designed to reduce the risk of deceptive or unfair pricing, improve price transparency, and help ensure consistent pricing practices across the Company’s retail store, website, and advertising.

This Review covers:

• In-store pricing: Shelf tags, signage, register/POS pricing, and quotes given by staff.
• Online pricing: Website product pages, cart/checkout pricing, and online ads.
• Sale pricing and comparison pricing: “Sale,” “Was/Now,” “Compare at,” “List price,” “MSRP,” “% off,” “save $X,” “clearance,” and similar claims.
• Price matching (if offered): Requirements to ensure any price match offer is clear, consistently applied, and not misleading.
• Fees treated as part of the advertised total price: Delivery fees, service/repair diagnostic fees, and any other add-on charges that are material to the customer’s purchase decision.

Note: This document is for informational and internal review purposes only and is not legal advice. The Company should have a licensed Florida attorney review these standards before final implementation.

2. Federal Regulations (FTC and Related Standards)

Money Saver AppliancesLLC’s pricing and advertising must comply with federal consumer protection standards, including Section 5 of the FTC Act (unfair or deceptive acts or practices) and the FTC’s Guides Against Deceptive Pricing (16 CFR Part 233). Key federal compliance points include:

• Truth-in-advertising (general rule): Price claims must be truthful, not misleading, and supported by documentation (for example, price history, competitor price checks, and promotion terms).
• Deceptive “former price” / “regular price” claims (16 CFR Part 233): If the Company advertises a “regular,” “was,” or “former” price, that reference price must be a bona fide price — meaning it was actually offered to the public in good faith for a meaningful period, not created just to make the discount look bigger.
• Deceptive comparison to competitor prices (16 CFR Part 233): If the Company compares its price to a competitor price, the competitor price should be real, current, and reasonably verifiable in the Company’s trade area (or clearly described if it’s outside the area or online-only).
• MSRP / “list price” claims (16 CFR Part 233): If the Company references MSRP or “list price,” it must not suggest savings from a list price that is not actually used in the relevant market. “MSRP” should be labeled clearly as a manufacturer suggestion, and claims of savings should be supportable.
• Bait-and-switch prohibitions:The Company must not advertise a product at an attractive price to draw customers in and then refuse to show/sell it, claim it’s unavailable when it is (or should reasonably be), steer customers to a higher-priced item, or impose undisclosed conditions that make getting the advertised deal unrealistic.
• Availability and quantity limitations:If stock is limited (or the offer is “while supplies last”), that limitation must be disclosed clearly and early in the customer’s decision-making process.
• “Free,” BOGO, and similar offers:Any conditions (minimum purchase, limited models, exclusions, shipping costs, or time limits) must be disclosed clearly; the “regular” price used to describe the value of the deal must be legitimate.

3. Florida State Regulations (FDUTPA and Related Florida Considerations)

Money Saver AppliancesLLC must comply with Florida consumer protection laws, including the Florida Deceptive and Unfair Trade Practices Act (FDUTPA), Fla. Stat. § 501.201 et seq. Under FDUTPA, deceptive, misleading, unfair, or unconscionable acts or practices in trade or commerce may lead to enforcement actions and civil liability.

Key Florida compliance points for pricing include:

• No misleading price representations: Price tags, ads, and online listings should not mislead customers about the price, savings, exclusions, or required conditions to receive an advertised price.
• Clear disclosure of material terms:Florida standards generally expect that material restrictions (model limitations, exclusions, required add-ons, short time limits, or “limited quantities”) are disclosed clearly.
• Consistency between advertised and charged price: The Company should ensure that the price a customer is charged matches what was advertised or displayed, subject to documented error correction protocols.
• Unconscionable pricing during declared emergencies: During a declared state of emergency, the Company should avoid any price increases on covered essential commodities that could be viewed as unconscionable under Florida law. (Even when appliances are not “essential commodities,” the Company should use extra caution in emergency periods and document any cost increases from suppliers.)

4. Sale Pricing Compliance (Regular vs. Sale, Comparison Pricing, and MAP)

To avoid deceptive pricing, sale and promotion claims must be based on real, supportable reference points.

A. “Regular” / “Was” / “Former” price rules

• The Company should only claim a discount from a “regular,” “was,” or “former” price if that reference price was actually offered to the public in good faith and not just set for advertising purposes.
• The “regular price” should be a bona fide price offered for a reasonable period before the sale. Because federal guidance does not set a single universal number of days, the Company should adopt an internal rule (for example, “regular price offered for at least 30 consecutive days” or another attorney-approved standard) and keep records to support it.
• If an item is almost always sold at the “sale” price, the Company should not present the higher price as the “regular” price.

B. “Compare at” / competitor comparisons

• Any “compare at” claim should identify the basis (Company former price, competitor price, MSRP) and must be supportable with documentation.
• Do not cherry-pick unrealistic competitor prices or outdated screenshots to inflate the claimed savings.

C. MAP (Minimum Advertised Price) compliance (major brands)

• MAP is a manufacturer/distributor policy (contractual), not a consumer price law, but violating it can cause serious business consequences (loss of co-op advertising, supply restrictions, or termination).
• The Company should keep current MAP sheets/policies on file, apply MAP to all “advertised” pricing channels covered by the policy (website, email, online ads, printed flyers, etc.), confirm whether “in-cart,” “at checkout,” “call for price,” or “in-store only” language is permitted under each brand’s MAP policy, and train staff not to publish sub-MAP prices in public advertising when prohibited.

5. Price Display Requirements (In-Store and Online)

The Company’s general rule is simple: the customer should be able to understand the price before committing to buy.

A. In-store price display

• Accuracy:Shelf tags and signage should match POS pricing. If they don’t, staff should follow the Company’s error correction protocol and document the correction.
• Clarity: Prices should be clearly associated with the correct product (model number/description) to avoid confusion when multiple similar items are displayed.
• Sale signage:Sale signs should include the key conditions (dates, exclusions, limited quantities, “select models,” etc.) in readable format.

B. Online price display

• Upfront product price: The product price should be clearly displayed on the product page.
• Fees and totals: Shipping/delivery fees and any required fees should be disclosed before final checkout confirmation.
• Taxes:Taxes should be calculated and shown at checkout (or earlier where practical). If taxes are not included in the displayed product price, the Company should avoid implying “out-the-door” totals unless stated.
• Currency display: Prices should be shown in USD unless the site clearly offers a customer-selected currency view. If a currency conversion is provided, it should be labeled as an estimate and the final charge currency should be disclosed.
• International duties/taxes disclosure:For international shipping of small items, the Company should clearly state that customs duties/taxes are the customer’s responsibility (unless the Company explicitly offers delivered-duty-paid terms).

6. Price Matching Policy Guidelines (If Offered)

If the Company offers price matching, it must be described accurately and applied consistently to avoid deceptive practices.

• Define who qualifies: public retail competitors (local or online), and whether marketplace sellers (third-party sellers) are excluded.
• Define what qualifies: same brand, exact model number, same condition (new vs. used), same included accessories/warranty, and in-stock/available for immediate purchase by the customer.
• Define what is excluded: clearance, closeout, open-box, refurbished, liquidation, bundle/contract pricing, membership-only pricing, limited quantity doorbusters, or pricing requiring financing or add-on services.
• Verification process: require a current ad, website listing, or verifiable quote; keep a screenshot or copy in the deal file.
• Timing: state whether price matches are available only at time of purchase (not retroactive) and whether they apply online, in-store, or both.
• No “phantom” price match claims:Do not advertise “We match any price” unless the Company truly does, because broad claims can be misleading if many exclusions exist.

7. Discount & Promotional Pricing (BOGO, % Off, Clearance, Limited-Time)

Promotional pricing must be clear about the deal, the conditions, and the true value.

• BOGO / “Free” offers: Clearly state what is free (same item vs. equal/lesser value), whether the customer must pay for the higher-priced item, and any limits (one per household, select models, etc.). Avoid inflating the base price before running the promo.
• Percentage-off discounts: The Company should clearly state what the percentage is applied to (regular price, MSRP, or specific category price) and ensure the reference price is legitimate and documented.
• Clearance pricing:Mark clearance items clearly and disclose that quantities are limited and sales may be final if the Returns & Refund Policy excludes clearance.
• Limited-time offers:If the Company says “today only,” “this weekend,” or “limited time,” it should be true. Include start/end dates and avoid repeatedly extending the same “limited-time” sale without a good-faith reason.
• Coupons and promo codes: Disclose material exclusions (brands, categories, minimum purchase, expiration, one-time use, non-stackable rules).

8. Recommended Compliance Procedures (Audits, Training, Records)

To make compliance easy and consistent, the Company should adopt written procedures and keep basic documentation.

• Pricing audits: Perform at least semi-annual audits (and spot-checks during major promotions). Include store signage, POS price files, and website pricing.
• Promotion checklist: Before launching any promotion, confirm start/end dates, eligible SKUs/models, inventory availability and raincheck approach (if any), reference price support, MAP compliance for applicable brands, and disclosure language for exclusions and limits.
• Staff training:Train sales, customer service, and marketing staff on what they can and cannot say about “regular price,” “lowest price,” “price match,” “free,” and “limited time,” when to escalate questions to management, and how to document price overrides and customer resolutions.
• Documentation and retention: Maintain organized records such as price history logs by SKU, promotion approval forms and ad copies, competitor price match verification screenshots, MAP policy sheets and updates, and corrected error logs. A reasonable retention period is at least 2 years (or longer if attorney-advised due to warranty or dispute timelines).

9. Liability & Disclaimers (Website and In-Store)

The Company should include clear disclaimers to reduce confusion and help manage mistakes — without using disclaimers to “hide” material terms. Recommended disclaimers (use where appropriate):

• Pricing errors / typos:“We make every effort to display accurate pricing. If a pricing or typographical error occurs, Money Saver AppliancesLLC reserves the right to correct the error and cancel or refuse any order placed for an item listed at an incorrect price, subject to applicable law.”
• Availability:“Prices and availability are subject to change without notice. In-stock status is not guaranteed until your order is confirmed.”
• Limited quantities:“Limited quantities available. No rainchecks unless expressly stated.”
• Taxes and fees:“Sales tax (where applicable) and delivery/shipping fees are calculated at checkout or at time of purchase.”
• Price matching disclaimer (if offered): “Price match is subject to eligibility requirements and exclusions. Ask in-store or see our policy online for details.”

10. Error Correction Protocol

In the event of a clerical or typographical error resulting in the publication of an incorrect price (online or in-store):

• The Company reserves the right to cancel orders placed at the erroneous price before fulfillment, as per the Terms & Conditions.
• Corrective action must be taken within 24 hours of discovery to update the website and point-of-sale systems.
• Customers affected by pricing errors shall be notified immediately and offered the option to proceed at the correct price or receive a full refund.

11. Audit and Review Frequency

Money Saver Appliances LLC shall conduct a pricing audit on a semi-annual basis. This review will include:

• Verification of current MSRP/MAP data from suppliers.
• Assessment of local competitor pricing to ensure “Small Store Prices” remain accurate.
• Evaluation of international shipping cost-to-charge ratios to ensure global customers are not overcharged.

12. Authorization

This Pricing Compliance Review has been reviewed and approved for implementation by the Company Owner.

King JAS
CEO / Owner
Money Saver Appliances LLC