Bulletin | May 2023

BULLETIN CO LO R ADO AU TO M O B I L E D EAL ER S ASSOC IATIO N

I N T HI S I SSU E CHANGES AT CADA EPA’S STRICTER EMISSIONS PASSWORD MANAGEMENT ESSENTIALS PHIL LONG’S HOMETOWN CHARITY

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M AY 2 023 | VOL U M E 2 4 | ISSUE 4

CONTACT US Colorado Automobile Dealers Association 290 East Speer Blvd., Denver, CO 80203 303.831.1722 info@colorado.auto www.colorado.auto

OUR STAFF Matthew Groves CEO matthew.groves@colorado.auto | 303.282.1449 Beth Weir Controller beth.weir@colorado.auto | 303.457.5120 Mark Zeigler Clear The Air Foundation Director mark.zeigler@colorado.auto | 303.457.5105 Khorrie Luther Business Manager khorrie.luther@colorado.auto | 303.457.5122 Dan Allison Member Services Coordinator dan.allison@colorado.auto | 303.831.1722

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BULLETIN | JUNE 2023

About Our Association Representing the franchised new car dealers of Colorado The Colorado Automobile Dealers Association (CADA) is the voice of the automotive retail industry throughout the state. As the automobile dealer trade association, CADA advocates issues of importance to the auto industry, Colorado auto dealers and Colorado’s driving public.

The Denver Automobile Dealers Association started in 1914 to operate the annual Denver Auto Show which dates to 1902. Colorado Automobile Dealers Association soon followed and both associations operated together with shared staff and a headquarters building. In 2010, after almost eight decades together the two associations became one. The history now dates over 108 years of high level automotive and mobility impact.

Today, our dealers range from small family-owned dealerships, to nationally operated, multiple franchise corporations. CADA represents a united front for over 300 new car, truck, motorcycle and RV dealers. From local, state and federal policymakers, to the public and the media, CADA is the voice for Colorado’s auto industry.

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Matthew Groves Interim CEO

Changing the Way We Communicate CADA is your voice at the Capitol. Our job is to determine your concerns, communicate them clearly to lawmakers and regulators and report back on how legislation and regulations impact your business. We have a responsibility to perform these tasks well – period.

Our communications have metastasized over my five years at CADA: advertisements, solicitations, aggregations of industry news and political whisperings.

We’ve cluttered your mailbox and consequently lost a lot of our credibility and also your trust.

When OTM stepped in to fill the void left by the departure of Kim Jackson, they pulled analytics on our communications department. They revealed CADA sent 100,000 emails in 2022. Clearly, CADA is overcommunicating with members. The Association cried wolf several thousand too many times. Predictably, readership fell – by startling numbers. Not only did we lose your attention, but we diminished the value of what we sent to the sponsors who helped pay for it.

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BULLETIN | JUNE 2023

I’ve made it my first priority as CEO to change the way – and amount – we communicate. I want to rebuild trust and re-engage you in our conversation. Another discovery we made was that as your General Counsel, when I sent a separate email or hosted Zoom meetings for your staff members – outside of our communications program – those emails were opened at a rate almost 65 points higher than our standard publications.

Why this huge discrepancy? I believe it could be my three-fold commitment to dealers: • We start meetings on time and end on time. As someone who loves to write, I avoid unnecessary words, written or spoken. You’ve probably also noticed that I don’t sit still well.

• I never ask you to ‘take it from me.’ I always cite a primary source or provide a government official to update you.

• I never ask you for money. My regulatory Zooms are always free to you – at your desk, because the information is more important than profit.

While the change in my job duties may have to alter that commitment to a degree (I am now responsible for our P&L), I still believe in outlining the relationship from the outset. So, here is what I am proposing for 2023 and beyond: 1. CADA is going to talk less and listen more. Our meetings will be discussions, not presentations. We’ll ask where you want to go, not tell you where we’ve been. We will do our best to engage everyone – even those who’ve taken a break from us. And we will always explain the why behind our decisions.

2. CADA will not regurgitate the news. You’re already reading industry publications and major media sources. We want to tell you what’s happening with us, not what’s happening in the world. Hopefully, this focuses your feedback into actionable items for the Board.

3. CADA will meet you at your level of interest. Like an Axios newsletter, we present headlines, a brief take, and resources to dig deeper. You can take and use what’s of interest to you.

You may have already noticed the change. By digitizing the CADA Bulletin in January, we saved a substantial printing and mailing expense. My goal is to make your Open Road fit on an 8 ½” x 11 ½” sheet of paper. If you can’t read while drinking a cup of coffee, it’s not effective.

More change is on the horizon. This spring, we will roll out a new plan for how we conduct CADA’s regional meetings and legislative grassroots meetings. We will focus more on individualized engagement and more time in dealerships, with less frenetic travel around the state. For now, though, I’m just asking you to stay tuned. I think you’ll like what you see.

Will Franchise Dealers Benefit from EV Market Volatility?

Financial analysts predict months of economic “volatility,” and among the most volatile sectors is automotive. Just look at how some automotive startups have fared. The realization that electric vehicles were going to become a serious market spawned a slew of new nameplates.

Some failed, some have limped and one – Tesla – has dominated the public’s imagination and become an economic juggernaut.

The new vehicles on offer are sexy. Many consumers enjoy feeling they’re on transportation’s cutting edge, but it comes with risks. Among them is these startups’ shaky financial underpinnings, especially during a period of volatility.

Stock Prices Fluctuate Wildly

Tesla has ridden a huge financial wave. By capitalization, it’s the eighth-largest publicly traded company in the world. But, as reported by Forbes Advisor, “Shares fell 65% during 2022 as interest rates rose and the tech sector got crushed (and the company’s CEO, Elon Musk, dallied with Twitter).

“This price collapse signals to investors how risky the EV space can be.” Stock prices rose on Musk’s announcement

at the mid-May shareholders’ meeting that the Cybertruck is coming this year, and the Roadster in 2024. Although Tesla’s been in business for almost 20 years, its first annual profit was in 2020; its Q1 profit was $2.5 billion, which was almost 25 percent less than Q1 2022.

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Signs of an EV Shakeout?

And some of the other better-known EV startups, e.g. Rivian, Lucid and Fisker? A report in the Washington Post (5/11/2023) trumpeted: “EV makers poised for a shakeout – just like the early days of auto industry.”

The report gathered these nuggets: • Valuation spiked at IPO: Lucid - $91 billion, Fisker - $8 billion and Rivian - $127. Tesla went public in June 2010, raising $226 million with a market cap of $2.3 billion.

• Market values are down 75 percent or more with large losses and falling cash: Lucid – Q1 loss = $779+ million; Fisker – Q1 loss = $120 million; Rivian – Q1 loss = $1.3 billion.

• Stocks are volatile: Tesla was at $409.97 in November 2021 - $182.90 on May 24, 2023; Lucid was at $55.21 in November 2021 – $7.60 on May 21, 2023; Rivian was at $172.01 in November 2021 - $14.38 on May 24, 2023; Fisker’s all-time high was $28.50 on February 26, 2021 - $6.79 on May 24, 2023.

Cox Automotive’s Michelle Krebs predicted a major upheaval is imminent, noting in the Post story that “ultimately there was a shakeout of just a few players and that just happened to be in Michigan…It’s déjà vu.” Higher interest rates are affecting startups’ funding acquisition, while established manufacturers with many franchise dealers can self-subsidize with revenues from gas-powered vehicle sales. They’re coming on strong, riding on profitability and ability to scale more quickly.

Affordability Is Still a Problem

J.D. Power reports that 26.9% of car shoppers say they are “very likely” to consider an EV. The number has stayed flat due to pricing and infrastructure concerns. Government subsidies only cover a few models because of requirements on assembly location and where battery and components originate. In fact, Tesla is the only non-legacy manufacturer whose models qualify for either full or partial government subsidy. Every other model that qualifies is made by Ford, GM or Chrysler/Jeep. Chinese offerings won’t be eligible, but Japanese and Korean makers, now considered “legacy brands” in the U.S., are racing to meet the criteria as they expand their EV offerings.

Business Insider reported, that “Chinese brands have mastered the quality and affordability of electric vehicles … are poised to arrive in the US” (5/16/2023). China sold about five million last year, compared to about 800,000 in the U.S. Contrast that with the ‘70s, when efficient Japanese imports disrupted the market and more recently, Korean brand penetration in SUVs. The report concluded, “History may repeat itself.

Chinese EV manufacturers can gain a foothold in the US by coming in at a budget price point, analysts said.”

Finally, there’s the question of how well startups are able to serve customers. Lucid only has “studios” in a handful of major metros and “Fisker Lounges” are even fewer. Rivian is still mostly direct-to-consumer, but has 34 service centers throughout the U.S. Pied Piper, a major secret shopper outfit released its 2023 “Prospect Satisfaction Index®” (PSI) ranking auto brands by PSI and “Internet Lead Effectiveness®.” Rivan, Tesla and Lucid were all ranked at the very bottom.

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BULLETIN | JUNE 2023

Safety first:

Password management best practices for dealerships In today’s world, managing an endless stream of passwords is a fact of life and business. Here’s how you and your employees can take steps to build stronger passwords:

Begin with these password essentials

Password security requires building unique, complex passwords that can’t be easily guessed. Start with these three best practices: • Make them long (aim for at least 10 to 12 characters, but 16 to 18 or even 20 is even better) • Avoid using common names, places and dictionary words • Use a random mixture of uppercase and lowercase letters along with numbers and symbols

Try turning a sentence or phrase into a password

Creating strong passwords is one thing, remembering them is another. To give your brain a break, consider a sentence or phrase you can easily recall. Then, combine that approach with the tips from above — by spelling out the phrase with letters, numbers and symbols.

For example: • I used to live in Wisconsin= iu$ed2l!vNW! • Summer rain clouds = suM3rra!nclwdZ

Give your memory a fighting chance

If you want to harness the power of a memorization method, apply the PAO (Person-Action-Object) method to your password creation. With this method, you visualize a person, an action and an object, then create a story. For instance, if your words are: Person: Tom Hanks Action: reading Object: coffee Then the story would be: Tom Hanks is reading with a coffee. Once you have the story down, create a password using the tips from above, like THnxRd!ngcf3e.

Don’t reuse the same password

Enable multi-factor authentication

Many sites and services have added additional layers of security to help protect users and avoid account breaches. Depending on the site, it may email or text a code to confirm your identity every time you log on. By enabling multi-factor authentication when possible, you can add another barrier between your personal information and cybercriminals.

Sign up for a password management service

Another way to keep track of your passwords is to sign up for a password management service for your business.

These services encrypt and store your passwords for you and even generate random new passwords when needed.

Generally, these solutions require a single master password that allows each user to access their stored information. Using one of these services for your business can help you get all of your employees on the same page with password security.

Security is the foundation of customer trust

The final piece is to make sure your whole team is following these best practices. Your business is only as secure as your weakest password, so make sure to distribute best practices and regularly remind team members to update and refresh their secured logins.

Using the same password for all your devices and accounts is the virtual equivalent of putting all your eggs in one basket. One data breach could put all of your information in jeopardy, everywhere you’ve used that password.

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Mark Ziegler

Director, Clear the Air Foundation

With the Denver Auto Show in the rearview mirror, I’m happy to report that the Hall of Fame and Preview Gala generated some much-needed revenue for the Clear the Air Foundation. This was accomplished in no small part by the following individuals who won trip auctions provided by AmFund: • Elizabeth Hayes – Spain Andalusia • Kim Calaway – Costa Rica • Allison Carow – Greece

• Evan O’Meara – Venice • Jasmine Bracamontes – Royal Chateaux & Champagne • Corey Hall – Scottish Highlands • Mike Ward – Tuscany Into the Wine • Nancy Ariano – Tuscany Into the Wine I hope all of you have a fabulous trip and thank you for your support! Your generosity is life-changing for the scholarship recipients.

Clear the Air Foundation 2023 Year-To-Date Vehicle Donations 7 Pueblo Dodge Chrysler Jeep Ram

1 Peak Kia North

6 Alpine Buick GMC South

2 Phil Long Honda of Glenwood Springs

5 A utoNation Chrysler Jeep Broadway

2 Schomp Ford 2 Schomp Hyundai

1 Phil Long Glenwood Springs Subaru

5 Mike Maroone Chevrolet South

2 Sill-Terhar Motors

1 Phil Long Valucar

5 The Faricy Boys

2 Stevinson Toyota East

1 Schomp Mazda

4 Dellenbach Motors

2 The Faricy Boys Ford

1 Stevinson Toyota West

4 O’Meara Ford

1 Castle Rock Ford

1 Subaru of Pueblo

4 Spradley Chevrolet

1 Durango motor Company

4 Summit Ford

1 Emich Chevrolet

3 Markley Motors

1 Emich Volkswagon of Boulder

3 Mountain States Toyota

1 Groove Toyota

3 Phil Long Ford of Denver

1 John Elway Chevrolet

3 Phil Long Ford of Raton

1 Johnson Auto Plaza

3 Schomp Honda

1 McDonald Automotive Group/ Audi Denver

3 Schomp Nissan 3 Schomp Subaru 2 Berthoud Motors 2 Hellman Motor Company 2 Perkins motors 2 Phil Long Ford of Motor City 8

BULLETIN | JUNE 2023

1 Mike Maroone Buick GMC 1 Mike Shaw Subaru 1 Morehart Murphy RAC 1 O’Meara GMC 1 O’Meara Volkswagen

1 Phil Long Ford of Chapel Hill

Other Donations 10 Fort Carson 5 Private Donation 1 Warren Tech

Dealer Total = 105 Other Total = 16 2023 YTD Donations Total = 121

River Bridge Regional Center Selected as Hometown Charity for 2022 Subaru Share the Love® Event Phil Long Glenwood Springs Subaru and Subaru of America support local child sexual assault victims; April is National Child Abuse Prevention Month GLENWOOD SPRINGS, Colo., April 25, 2023 – Phil Long Glenwood Springs Subaru presented a check in the amount of $15,500 to River Bridge Regional Center earlier today as a part of the 2022 Subaru Share the Love® Event. This is the second year-in-a-row the nonprofit was selected for their impact and support provided to the growing number of child sexual assault victims in Pitkin, Garfield, Eagle, and Rio Blanco counties. The check presentation occurred at 12 p.m. at the dealership, with representatives from Subaru of America, Phil Long Dealerships, Glenwood Springs Chamber of Commerce and River Bridge, along with employees and partners of the retailer.

This year’s donation, a sizeable increase from the prior year’s $13,000, will be directed to the nonprofit’s Bridges to their Futures Campaign. The aid will help over 250 children this year receive supportive services from River Bridge, including forensic interviews, mental health assessments, therapy, referral, medical treatment or consultation, and provide the community with child abuse awareness and prevention education.

According to the Centers for Disease Control and Prevention, an estimated 1 in 4 girls and 1 in 13 boys in the United States experience child sexual abuse. Nationally recognized in April, Child Abuse Prevention Month highlights the importance of families and communities working together to prevent child abuse and neglect.

“The Subaru Share the Love® Event brings together our employees and customers to make a difference in our community,” said Carroll Winkler, general manager of Phil Long Glenwood Springs Subaru. “It is extremely gratifying to know that we are directly helping our vulnerable children to receive the help they need to move forward to rebuild their lives and forge brighter futures. I am thankful for Subaru of America for their commitment, to River Bridge for their continued impact, my dedicated employees, and our customers, who are the driving force in our ability to provide this assistance.”

As part of the Subaru Share the Love® Event, retailers were able to select a hometown charity that touched their local community’s heart and met various requirements, including the charity does not harm animals, is environmentally responsible, and ensures donations are being used for the charitable mission and not administration costs.

From November 17, 2022 to January 3, 2023, with every new Subaru purchased or leased, Subaru of America and Phil Long Glenwood Springs Subaru, together, donated $325 to each customer’s choice of local or national charities, including River Bridge Regional Center, The American Society for the Prevention of Cruelty to Animals®, Make-A-Wish®, Meals on Wheels America and the National Park Foundation. Additionally, Subaru of America and the retailer provided a donation for every Phil Long Subaru vehicle routine service visit during the campaign period.

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“Phil Long Subaru understands the importance of supporting our community’s nonprofits, the unique services, and the quality of life they provide for our community. River Bridge is honored to be a recipient of this year’s Share the Love Giving Campaign, helping raise funds to support our child victims of abuse and non-offending family members with the essential services to promote hope and healing,” said Mary Cloud, development director of River Bridge Regional Center. “Together we are coming closer to creating a community where children are safe, families are strong, and where all abused children are believed, supported and able to heal.”

Over the last 15 years, through the Subaru Share the Love Event®, Subaru of America, Inc. and participating Subaru retailers have donated more than $256 million to charity, with customers choosing between four national charities and over 2,100 hometown charities.

Phil Long Glenwood Springs Subaru received the 2023 Subaru Love Promise Community Commitment Award, which nationally recognizes Subaru retailers who are making a world a better place while demonstrating an outstanding commitment to supporting passions and causes in local communities, such as the environment, community, health, education, and pets. Phil Long Subaru has been recognized by the manufacturer eight times for excellence over the last eleven years.

ABOUT RIVER BRIDGE REGIONAL CENTER River Bridge Regional Center is a nationally accredited nonprofit child advocacy center, utilizing a childcentered, multidisciplinary approach to the prevention, assessment, treatment, and investigation of child abuse. River Bridge has served 2,831 children and 2,169 caregivers since opening in 2008.

ABOUT SUBARU OF AMERICA (SOA) Headquartered in a zero-landfill office in Camden, N.J., the company markets and distributes Subaru vehicles, parts, and accessories through a network of more than 630 retailers across the United States. SOA is guided by the Subaru Love Promise, which is the company’s vision to show love and respect to everyone, and to support its communities and customers nationwide. As a company, Subaru believes it is important to do its part in making a positive impact in the world because it is the right thing to do.

ABOUT PHIL LONG GLENWOOD SPRINGS SUBARU Phil Long Glenwood Springs Subaru is a community-driven, award-winning, and successful new and pre-owned vehicle and full-service dealership located in Glenwood Springs. In June, 2021, Phil Long Glenwood Spring Subaru became the 18th dealership of Phil Long Dealerships and its second location in Western Colorado.

Phil Long Glenwood Springs Subaru is located at 175 Storm King Road in West Glenwood Springs, CO, a convenient drive from Rifle, Carbondale, Eagle and Aspen. Showroom hours are Monday through Friday, 8am – 6pm, and Saturdays, 8am – 5pm. For more information, call 970.945.7447, follow us on Facebook or visit phillongsubaru.com to view our online inventory.

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BULLETIN | JUNE 2023

Matthew Groves Interim CEO

What the EPA’s Stricter Emissions Proposal Means The Environmental Protection Agency announced two major rules in April that impact the adoption of Zero Emission Vehicles (ZEVs).

Phase III of the greenhouse gas regulation mandates stringent emissions guidelines for trucks and buses in the 2027-2032 model years.

New emissions standards for light and medium duty vehicles, requiring that 67% of new sales must be zero emissions by 2022. This will have a significant impact on dealers.

Perhaps this seems like a non-story because the state of Colorado will adopt the second iteration of California’s Clear Car Rule (ZEV II) this summer, which theoretically will place us on a trajectory to hit 80% ZEV market penetration by 2032. What’s our concern about increasing the federal standard when Colorado’s is more stringent?

Four potential issues come to mind: The Colorado regulation likely faces some legitimate legal concerns and federal pre-emption challenges that could result in the state regulation being overturned in court and forcing Colorado to adopt the federal standards.

The federal government and California have battled over which one takes precedence on mobile source emissions for almost two decades. It’s revealing that when a National Highway Traffic and Safety Administration (NHSTA)

bureaucrat left for the California Air Resources Board, he commented to the media that he considered the two bodies to be co-equals. The federal government wants to establish its pre-eminence by closing the gap between the two entities’ regulations.

Equally important is how much federal regulation moves the market. A handful of OEMs have had a handshake agreement with California to move to electric earlier than required. The federal rule validates that agreement and disadvantages those manufacturers who did not participate, many of whom were holding out to lead the charge on non-electric zero emission technologies.

Finally, these requirements are on vehicles “offered for sale,” but not necessarily sold. So, if manufacturers aren’t able to produce enough ZEVs because of critical mineral shortages and supply chain issues, for example, the easiest way to meet the 67% threshold is to cut back on the overall supply of vehicles for sale. That could lead to long-term inventory challenges for both dealers and manufacturers.

Vehicle pricing would become a very unfortunate victim of these poorly considered jolts to supply and demand.

As interest rates are rising and the average new car price approaches $50,000, it only exacerbates overall strain on the consumer market. NADA will emphasize this point when it submits comments to the EPA ahead of the rulemaking.

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CADA also participates in the rulemaking through its membership in the American Highway Users Association, which intends to submit comments as well, based on feedback from its membership.

We will keep you updated on the progress of this rule. We are well represented, which is important because the rule’s immediate impact will be felt for years to come.

IRS Fumbles EV Tax Credit Guidance

CADA has released dealer memos in the last several months detailing the evolution of the EV Tax Credit established in the 2022 Inflation Reduction Act (IRA). It seemed that once the ‘new credit’ began on January 1, 2023, that we’d found steady footing, but new IRS guidance effective April 18, 2023 is creating chaos, instead.

The tax credit applying to the purchase of new electric vehicles – the IRA’s Section 30(D) – is the issue, since leases and used credits are defined separately. As originally understood, the 30(D) credit would amount to $7,500 for every qualifying vehicle. That is no longer correct.

The new rule for qualifying for the federal tax credit is based on the battery and critical mineral requirements, which will depend on where the component minerals are sourced. These changes are based merely on the IRS’s interpretation of the IRA rather than any subsequent legislation. Nevertheless, the impact is the same.

The credit essentially has two parts: Vehicle owners will receive $3,750 if the minerals in the vehicle are sourced from approved countries, and received an additional $3,750 if the materials in the battery are as well.

The regulation cuts down qualifying EV models from 41 to 22, and only 14 remain eligible for the full $7,500 tax credit. The remaining eight models are eligible for just half - $3,750. NADA points out that many of these newly disqualified models will still qualify for a tax credit under Section 45(w) if they are leased instead of purchased.

Here is a list of the vehicles qualifying for the full or partial tax credit (all are 2023 models unless noted).

Full Credit ($7500)

Partial Credit ($3750)

No Longer Qualify

Chrysler Pacifica Plug-In Hybrid

Jeep Wrangler Plug-In Hybrid

Audi Q5 TFSI e Quattro Plug-In Hybrid

Ford F-150 Lightning

Grand Cherokee Plug-In Hybrid

BMW 330e Plug-In Hybrid

Lincoln Aviator Grand Touring

Ford E-Transit

BMW X5 xDrive45e Plug-In Hybrid

Chevy Bolt and Bolt EUV

Ford Mustang Mach-E

Genesis GV70

Cadillac Lyriq

Ford Escape Plug-In Hybrid

Nissan Leaf

2024 Chevy Silverado

Lincoln Corsair Grand Touring

Rivian R1S

2024 Chevy Blazer

Tesla Model 3 (Standard Range, Rear Wheel)

Rivian R1T

2024 Chevy Equinox

VW ID4

Tesla Model 3

Volvo S60

Tesla Model Y

NADA has compiled a list of additional resources available at their webpage, www.nada.org.

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BULLETIN | JUNE 2023

Real-Time Insights for Sales Success: Effectv’s Partnership with AUTOFLYTE EDGE Keeps You Ahead of Emerging Trends You know your sales numbers as of right now, but do you know your competitors? Do you know where they are gaining share? Or which models/segments are trending in your target geography today? Do you know where other OEMs are selling or where it’s best to conquest specific models?

Effectv’s partnership with AUTOFLYTE EDGE allows dealers to respond to emerging trends in real time.

Capitalize on opportunity with insights that allow you to pinpoint exactly where your sales opportunities are by model, geography, and competitor while there is still time to affect this month’s sales outcome.

Effectv uses these valuable insights to better understand the current market trends. Third-party partnerships, combined with first-party aggregated Comcast viewership data, allow Effectv to develop strategies to deploy smart video campaigns that are designed to reach the right target audience in the right geography, helping you achieve your sales goals.

Effectv wants to ensure advertisers get the most impactful results, so our investment in their success doesn’t stop once the campaign begins. We continually evaluate the products and schedules being used, as well as look at reporting tools to determine what optimization should be employed to generate the greatest return on investment. Effectv can help drive more website and foot traffic for Colorado dealerships.

Need creative? We’ve got you covered! Effectv’s awardwinning creative agency, Mnemonic, can help brands deliver impactful messaging that resonates with car and truck buyers. Watch samples of some of their work.

Visit our website to learn more or contact Kristen Lucero, Effectv’s Automotive Sales Manager in Colorado, to set up a meeting to review your sales, gain competitive insights, and develop a high impact video strategy for your dealership:kristen_lucero@comcast.com, 303-603-0751.

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BULLETIN | JUNE 2023

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