Issuu on Google+

N E W

J E R S E Y

I N D E P E N D E N T

DEALER

A U T O M O B I L E

D E A L E R S

A S S O C I A T I O N

NEWS J U N E / J U LY 2 0 1 4

magazine

CRM VS BDC Keeping Your Cart Full of Customers

u inside

• Action Against NY Lender • Insights into Customer Experience • Compliance Overdrive

DALLAS, TEXAS Permit No. 2079

PAID

PRSRT Standard U.S. Postage

W W W . N E W J E R S E Y I A D A . O R G

NJ_0614.indd 1

5/19/14 11:09 AM


NJ_0614.indd 2

5/19/14 11:09 AM


NJ_0614.indd 3

5/19/14 11:09 AM


AUCTION NEWS

Subaru Announces Auction of Year MANHEIM NEW JERSEY RECEIVES HONOR

INSIDE

06 Action Against NY Lender 08 CRM vs. BDC 10 Weathering Storms of Regulation 12 Insights into Customer Experience 14 Buying a Used Car 16 Washington Update 20 Remote Buyers 22 Compliance Overdrive

WHAT’S NEW Tire Safety Week

BE TIRE SMART

Mark your calendars for the 2014 National Tire Safety Week June 1-7. The event is sponsored by the Rubber Manufacturers Association to raise consumer awareness about tire safety. Help consumers keep their tires safe and demonstrate your commitment to motorist safety. Sign up for free materials at www.rma.org/tire-safety/tire-safety-week.

PRODUCTS

& SERVICES

New ID Scanner Combats ID Fraud at Dealerships ID FRAUD IS A GROWING PROBLEM FOR DEALERS

National Independent Automobile Dealers Association www.niada.com • www.niada.tv 2521 Brown Blvd. • Arlington, TX 76006-5203 phone (817) 640-3838

In 2013, nearly one billion identities were breached, enabling criminals using supersophisticated technology to make impeccablelooking fake IDs. More thieves are now using fake IDs to test-drive and steal – or even purchase – cars. Dealerships typically use barcode scanners that can only verify that data is present on a card, not its validity, leaving them vulnerable. A recent case study from The Benny Boyd Auto Group showed how one group is utilizing ID scanner technology to not only eliminate fraud, but to also realize some unexpected benefits, including an increase in sales. The scanner, which utilizes the same technology used by Homeland Security, helps them capture more leads and cut the average sales and finance process by 30 minutes because the scanner connects the customer’s information to sales and financing at the point of scan. The case study also reported several other benefit areas, from federal compliance laws mandating protection against employee identity theft to greater salesperson accountability, to

For advertising information contact: Troy Graff (800) 682-3837 or troy@niada.com.

INDUSTRY

ADVERTISERS INDEX 4

Subaru of America recently announced its 2013 Auction of the Year, an award based on sales effectiveness and service quality. Taking this year’s honors is Manheim New Jersey. Subaru determines the winning auction by tracking and measuring three key components: total sale percentage, retention to goal price and number of unique buyers. “A numerical score is calculated at the conclusion of every sale at every location on a monthly basis, and the auctions are ranked monthly based on the final score,” said John Manchin, national fleet remarketing manager at Subaru. Manheim New Jersey is among several facilities hosting combined Subaru factory sales – featuring company, promotional and program vehicles – and Subaru Motors Finance sales, featuring consumer off-lease vehicles.

ADESA.................................. Inside Front Cover Ally.....................................................................9 Auto Auction of New England...........................7 Auto Use..........................................................16 Black Book.........................................................3 Manheim.com....................... Inside Back Cover Manheim New York...........................................5 Manheim Pennsylvania...................................15 NextGear Capital.............................................13 Preferred Warranties....................................... 11 Stars GPS........................................................12 United Acceptance..........................................17 VAuto ................................................Back Cover

OFFICE

For information on how to become a member, please contact Paula Frendel (855) 694-2324 paula@newjerseyiada.org www.newjerseyiada.org

NIADA HEADQUARTERS

The New Jersey Dealer News is published bi-monthly by the National Independent Automobile Dealers Association Services Corporation, 2521 Brown Blvd., Arlington, TX 76006-5203; phone 817-640-3838. Periodicals postage paid at Dallas, TX and at additional offices. POSTMASTER: Send address changes to NIADA State Publications, 2521 Brown Blvd., Arlington, TX 76006-5203. The statements and opinions expressed herein are those of the individual authors and do not necessarily represent the views of New Jersey Dealer News or the National Independent Automobile Dealers Association. Likewise, the appearance of advertisers, or their identification as members of NIADA, does not constitute an endorsement of the products or services featured. Copyright © 2014 by NIADA Services, Inc. All rights reserved. State Magazine MGR./Sales Troy Graff • troy@niada.com Editors Andy Friedlander • andy@niada.com Jacinda Timmerman • jacinda@niada.com Magazine Layout & Graphic Artist Chantae Arrington • chantae@niada.com Art Director Christy Haynes • christy@niada.com Printing Nieman Printing

DEALER NEWS

NJ_0614.indd 4

J U N E / J U LY 2 0 1 4

protecting his team from criminals using fake IDs to take test-drives then pulling guns on salespeople. With one scan, ID Drive performs dozens of complex forensic tests on IDs in seconds. It extracts all biometric and alphanumeric data in the document, and authenticates it using its forensics library and detection algorithms, scrutinizing not only visible ID properties, but also those undetectable to the eye. The result: instant validation or red flags. ID Drive also extracts, purifies and enhances the personal information on the ID, and seamlessly exports it into a dealership’s CRM/finance systems. To read the full case study, visit http:// www. elendsolutions.com/case-study/case-study-2/. ABOUT ELEND SOLUTIONS: ELEND SOLUTIONS WAS FOUNDED IN 2003 AS DEALERCENTRIC, WHOSE “GET PRE-APPROVED IN SECONDS” SOLUTION REPRESENTS THE AUTO INDUSTRY’S LEADING ONLINE CREDIT APPLICATION PRODUCT. THE COMPANY HAS SINCE EXPANDED ITS MISSION BY DEVELOPING A COMPREHENSIVE, NEXT-GENERATION CONSUMER FINANCE MANAGEMENT SYSTEM FOR DEALERS, LENDERS AND CONSUMERS.

NEWS

2014 NIADA Used Car Industry Report Get a sneak peak of the upcoming 2014 NIADA Used Car Industry Report at this year’s NIADA Convention & Expo. You’ll be able to pick up an advance copy in the NIADA convention exhibit hall. Simply visit the NIADA Dealer Lounge located in the center of the expo hall. Look for your mailed copy the first week of July. Compare your dealership statistics with those nationwide and get the latest facts and statistics on the used vehicle industry based on proprietary research by some of the best known industry analysts. Get an overview of the independent used car dealer and used vehicle marketplace. Included this year is the entire 2014 NAAA Market Report. W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:09 AM


NJ_0614.indd 5

5/19/14 1:59 PM


LEGAL

MARKET

NEWS

Dodd-Frank Power Triggers Action Against NY Lender

6

ALLEGATIONS OF A LONGSTANDING SCHEME TO STEAL MILLIONS FROM CUSTOMERS The Dodd-Frank Act provided the foundation for more regulation of auto financing by federal regulators. Now a state-level agency is leveraging Dodd-Frank to seek orders against a New York-based subprime lender. Benjamin Lawsky, New York’s superintendent of financial services, recently obtained a temporary BENJAMIN LAWSKY, NEW YORK’S SUPERINTENDENT restraining order in federal court OF FINANCIAL SERVICES, OBTAINED A TEMPORARY against subprime auto lender Condor RESTRAINING ORDER IN FEDERAL COURT AGAINST CONDOR CAPITAL CORP., A SUBPRIME AUTO LENDER Capital Corp. and owner Stephen HEADQUARTERED ON LONG ISLAND, AND ITS Baron. OWNER, STEPHEN BARON. Lawsky explained a DFS investigation uncovered that a positive credit balance owed to Condor has allegedly engaged you, you may file a complaint with in a longstanding scheme to the New York State Department of steal millions of dollars from its Financial Services.” customers — among other unfair, According to Condor’s most recent abusive and deceptive practices. As annual report filed with DFS, at the part of its ongoing legal proceeding, end of 2013, Condor held more than DFS is seeking restitution for Condor 7,000 loans to New York customers consumers, disgorgement of profits, with total outstanding balances of the appointment of a receiver to more than $97 million. That report wind down Condor’s operations and showed Condor’s 2013 loan portfolio other remedies. contained aggregate outstanding According to Lawsky, the loans of more than $300 million proceeding against Condor is the nationwide. first legal action initiated by a state As alleged, rather than notifying regulator under section 1042 of the customers of positive credit balances federal Dodd-Frank Wall Street and promptly paying them refunds, Reform and Consumer Protection agency officials said Condor has “for Act. Lawsky noted the provision years knowingly and systematically empowers state regulators to bring hidden the existence of the positive civil actions in federal court for credit balances and retained them violations of Dodd-Frank’s consumer for itself, and has maintained a protection requirements, and obtain policy of refusing to refund them restitution for abused customers and except when expressly requested by other remedies provided for under a customer.” that law. Condor is also alleged to have Condor is a finance company endangered the security of its that acquires and services loans customers’ personally identifiable to customers in New York and information, placing them at serious more than two dozen other states, risk of identity theft. Among other including New Jersey. information-security lapses, the DFS The company mentioned the suit examiners found stacks of hundreds on its website. of hard copy customer loan files lying “Pursuant to a court order, around common areas. Condor Capital Corp. is not currently State officials noted that Condor accepting new loans or applications also has failed “despite repeated for new loans,” officials said. directives from DFS” to adopt basic “Existing and former customers policies, procedures and controls of Condor Capital Corp. continue to ensure that its information to have access to their accounts technology systems and the through this website. customer data they contain are “If you are a current or former secure. DFS said it reviewed and customer of Condor Capital Corp. analyzed numerous complaints and you believe that you may have about Condor. DEALER NEWS

NJ_0614.indd 6

J U N E / J U LY 2 0 1 4

WATCH

Used Cars Are Going to Keep Getting Cheaper and Cheaper ONE AFTEREFFECT OF THE GREAT RECESSION IS ON DISPLAY NOW AT CAR DEALERSHIPS, WHERE THERE ARE MORE AND MORE USED CARS FOR SALE AT INCREASINGLY LOWER PRICES. The used car market has gone a bit haywire over the last half-dozen years. During the height of the Great Recession, new auto sales of all shapes, sizes and variations tanked. As a result of relatively few new cars being purchased, there were fewer used cars on the market during the years that followed – years when the economy was still struggling, when demand for cheap vehicles was understandably high and when used car prices soared because there weren’t enough pre-owned vehicles for sale to keep up with demand. Signs of a softening in used car prices began appearing around 2012 and now consumers can expect better pricing and a more robust selection of most models. In particular, a trend that’s stretched for several years in the lease market will soon result in a “used-car flood” at auto dealerships, as Automotive News put it. Leasing, which slumped during the peak recession years, has rebounded considerably lately. In 2009, according to Edmunds.com, consumers scooped up only 1.5 million or so new cars via three-year lease, down from nearly 2 million the year before. Fastforward three years after that low for leasing, and in 2012 there were only about 1.5 million off-lease used cars hitting the market – an exceptionally small number compared to the high of 3.4 million in 2002, per the Manheim Used Car Market report. Because the pace of used-car leases has picked up each year after 2009, so too have the ranks of used cars going up for sale

three years later, when the lease terms are up. This year, roughly 2.1 million off-lease vehicles will be back on the market, up from 1.7 million in 2013. Next year, the number of off-lease used cars for sale should swell to 2.5 million, and in 2016 and for the foreseeable future, Manheim predicts that there will be more than 3 million off-lease vehicles returning to the market annually. Add in the fact that cars have increasingly longer life spans, and we’re seeing an acrossthe-board rise in supply of used cars – and the increasing supply is projected to translate to lower prices. Earlier this year, Edmunds.com forecast that used-car prices would slide 2 percent in 2014, and perhaps further down the road as a result of leasing trends. “Many car shoppers might not realize how much the new- and used-car markets feed off each other,” explained Edmunds.com senior consumer advice editor Philip Reed. “The boom in new car leases, for example, is leading to a higher number of lease returns, which adds to the growing inventory of used cars, forcing their prices down.” The news isn’t all good for consumers, however. A decrease in used-car prices also means that drivers will get less for used vehicles they’re trading in or selling. That shiny new car you purchase is likely to lose its value more quickly than it would have in the recent past. Individual car buyers also tend to simultaneously be sellers of their older cars, and from the looks of things, it’ll be a buyer’s market for quite some time. TIME.COM

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:09 AM


NJ_0614.indd 7

5/19/14 11:09 AM


BHPH

PERSPECTIVES

CRM VS BDC EITHER, NEITHER OR BOTH

8

Is a CRM right for you? Maybe a BDC is what you need. Whether they realize it or not, every Buy Here-Pay Here dealer has some form of both. Or at least they better if they want to survive. Let’s start by defining each of these to clear things up a little. I wouldn’t want anyone running out and spending money on something they already have and just don’t realize it. CRM, or customer relationship management, by definition is simply a strategy for managing and nurturing a company’s interactions with customers and sales prospects. Technology is usually involved in the form of a software package that helps organize, automate and synchronize sales related activities as well as marketing and customer service activities. A CRM’s goals are to find, attract and win new customers; nurture and retain those you already have; entice former customers to not be former customers and help reduce the cost of marketing and customer service. Sounds a whole lot like a repeat and referral program, doesn’t it? Something every BHPH dealer should already have. Using some sort of a software package to help manage your CRM is a necessity. That doesn’t mean you need to go out and purchase one specifically for a CRM. The software that you currently use for your day to day BHPH operations should be able to produce reports of customers with low balances and customer paid out reports. All you need to do is make sure you have in place a process for working those low balance customers and customers that have recently paid off in addition to the potential customers given as referrals from current customers or other sources. It needs to be

u To

a simple follow up plan that a manager is responsible for instituting and can be as simple as a call log that the salesperson has to turn in. As your business grows, it may be necessary to seek professional help, so to speak, and invest in a software package that can better manage these tasks. Handwritten logs are fine when you’re talking about 10-20 contacts. When that number gets to 100-200, it’s time to get a little more sophisticated. A truly effective CRM will cover not only sales but a service center as well. Both need new customer development, current customer retention and previous customer renewals. And since they are an integral part of customer service, both can have an effect on collections, both positive and negative. A poorly managed CRM means poor customer service. Poor customer service from the sales or service departments to current customers can make it difficult to collect from them much less resale them. Poor customer service to previous sales or service customers means no return business from them and pretty much ensures no referral business. You know the old adage: “A satisfied customer will tell five people about their experience. A dissatisfied customer will tell 20.” But that’s another article entirely. BDC, or business development center, is exactly what the name implies – a center to develop business. This is usually a department within an organization whose sole purpose is to get prospective customers through your doors. Their goal is to set as many appointments as possible. This is done through calling referrals given by customers and Internet

be truly successful, dealers are going to have to become more efficient at maximizing repeat business and holding on to customers, and turning new leads into sales. DEALER NEWS

NJ_0614.indd 8

J U N E / J U LY 2 0 1 4

BY BRENT CARMICHAEL

leads, and handling incoming calls to the dealership. Hopefully a fair amount of those appointments will show. Then it’s up to your sales staff to close the deal. A BDC can be as simple as your current sales staff or as in depth as including business development representatives, team leaders and business development managers. The level of staffing depends on the number of leads you have. As with a CRM, a BDC can be used for both sales and service. It too can have a positive and negative effect on collections for all the same reasons. A specific software package is not a necessity for an effective BDC. A simple process for routing incoming calls and Internet leads to a salesperson, along with a process for when and how to work referrals, is all you really need. As your lead volume grows, so must your ability to effectively manage them. That will be the time to call in the professionals and find good BDC software to help manage all those leads. As with a poorly managed CRM, a poorly managed BDC can not only cost you sales and service business, but can cause collections issues. By definition, every BHPH dealer has, or should have, both of these systems in some form. If they have a process for generating repeat business or have a referral program, they have a CRM. If their salespeople are taking incoming sales calls or working Internet leads, they have BDC. I shudder to think there might be a BHPH dealer out there that doesn’t have both of these. The biggest question is whether they are managing them as such. And by that I mean, do they have a process and procedure in place for these, do they have goals and expectations for each and do they have follow up and accountability in place? The successful dealers, I can assure you, do. To be truly successful, dealers are going to have to become more efficient at maximizing repeat business holding on to customers, and turning new leads into sales. Both of these can only be accomplished through a CRM and BDC in some form. With the current state of the economy, there are more customers in the BHPH arena than ever before. There is also more competition for those customers, so accomplishing the aforementioned has gotten a lot more difficult. To ensure long term survival, dealers have to manage both their CRMs and BDCs. BRENT CARMICHAEL IS ONE OF THE INDUSTRY’S MOST WELL RESPECTED BUY HERE-PAY HERE EXPERTS. HE IS EXECUTIVE CONFERENCE MODERATOR FOR NCM ASSOCIATES, INC. PRIOR TO JOINING NCM, BRENT WORKED 17-PLUS YEARS IN SUB-PRIME FINANCE AND COLLECTIONS.

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:09 AM


NJ_0614.indd 9

5/19/14 11:09 AM


COMPLIANCE

MATTERS

Weathering the Inevitable Storms of Regulation BUILD ON A SOLID FOUNDATION

10

I was fortunate enough to grow up with a father who was a home builder. I learned that his financial success wasn’t directly related to how well he built homes, but rather how well he navigated the political bureaucracies that existed in the markets in which he built homes. Obstacles such as endangered species, million-year-old whale skeletons and power-hungry city councilmen all stood in his way of completing projects. His ability to adapt his business to factors unrelated to home building ultimately contributed to his success. I have had the privilege of working in the automotive industry for the past 11 years. I’ve seen dealers face what seemed to be insurmountable obstacles and overcome. I’ve also seen dealers fail to adapt to increased regulations and market pressures and, as a result, close their doors. The lessons I’ve learned in the automotive space are similar to the lessons my father taught me. If we are to survive and be successful, we have to build our businesses on firm foundations with solid business processes so we can weather the many storms on the horizon. A new obstacle that has the potential to change how many dealerships run has to do with the Dodd-Frank financial reform law, which recently created a new federal agency called the Consumer Financial Protection Bureau. Dealers now face the risk of being investigated when consumers complain

to their attorney general and other public forums. Since we live in a consumer-friendly environment, it is critical for dealers to adapt to this legislation by improving their business processes to not only better handle and document customer complaints but also proactively document the many successes with customers. Creating an effective consumer complaint procedure can capture and resolve many problems before they ripen into regulatory complaints. Reducing the number of complaints made to regulators is probably the most important thing a dealer can do to reduce the risk of being targeted by the CFPB. To help dealers overcome this obstacle, DealerSocket CRM has adapted its technology to effectively manage consumer complaints. Consumers can submit surveys online or call the dealer directly to log a complaint. Once the complaint is logged, the dealer has the option to automatically assign the complaint to an individual or team to solve. If a certain number of days pass before a complaint is resolved, the issue can be escalated to a manager or higher authority within the dealership. As an added bonus, surveys received from happy customers automatically get directed to online/social reputation sites (Google Review, Yelp, Facebook, etc.), improving a dealer’s online reputation by increasing their positive reviews. Showing a

BY PETER ORD

4+ star rating on Google has the potential to decrease a dealer’s risk of being investigated, which in turn could save thousands of dollars. Since 95 percent of consumers use at least one social media outlet, it’s more important than ever to have a complaint management process to give your customers the communication path to voice their complaints with you first. Even if the CFPB didn’t exist, these business practices have been proven to help your business. A recent study by NADA found that if dealers are able to effectively resolve a customer complaint, they are four times more likely to retain them as a repeat customer than if they never submitted a complaint in the first place. This means that complaints can actually be a blessing in disguise for your dealership. Customer complaints aren’t the most pressing issues dealers face on a day-to-day basis, but the prompt resolution of an issue sets your dealership apart from others while securing customer loyalty. It has been said that data is the new oil for the 21st century. It is critical that we use data not only to help leverage new sales opportunities, but to also protect us from costly investigations that could come our way. PETER ORD IS DIRECTOR OF SALES FOR THE INDEPENDENT MARKET FOR DEALERSOCKET. HE IS RESPONSIBLE FOR LAUNCHING DEALERSOCKET’S NIADA ENDORSED CRM INTO THE INDEPENDENT SPACE. HE HAS FULFILLED THE RESPONSIBILITIES OF CUSTOMER SUPPORT, CONSULTING, TRAINING, AND BUSINESS DEVELOPMENT. HE CAN BE REACHED AT PORD@DEALERSOCKET.COM.

DEALER NEWS

NJ_0614.indd 10

J U N E / J U LY 2 0 1 4

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:09 AM


NJ_0614.indd 11

5/19/14 11:09 AM


SALES

MATTERS

Insights into Customer Experience IT’S A RELATIONSHIP-DRIVEN BUSINESS

We are all consumers. As a consumer, what is it that you truly desire when doing business with a company? Sure, you expect to pay a fair price for whatever product or service you purchase. Moreover, you should perceive value for the money you are spending. Isn’t there a lot to be said about the overall customer experience? Your basic expectation is a successful

12

transaction, but shouldn’t you expect more? If the answer to this question is yes, then you should take into account your overall customer experience with the individuals and companies you do business with. Everyone wants to feel like they matter, and most people seek a certain degree of satisfaction that inspires repeat business.

BY GARRETT JOREWICZ

What do you do to create a positive customer experience? Most people like it when someone genuinely cares about their best interests. However, how many people like it when someone tries to sell them something? Essentially, people love to buy, but hate to be sold. This holds true for the car buying experience, which is consistently ranked as one of the most stressful purchases someone will make. Customers don’t want to feel like they are being pressured into buying a certain vehicle or add-ons. In general, most of them know what kind of car they want and what they want to pay. If they have contacted you about a car or come to your lot, the hardest part – getting them onto your lot – is done. Now the key is to provide the experience that enables you to close the deal. Two weeks ago, I decided to get a new car. I found the dealership that had the best selection of the car I wanted. I set clear expectations with the salesperson of what they could expect from me. I told them exactly what I wanted from them and I asked if they would like to proceed. I was assured that they would work with me under those terms. While I may be in the industry, on this day I was a consumer seeking a hassle-free experience at a fair price. In reality, they just wanted to get me in the door, upon which they then proceeded to change their initial agreement. Unable to resolve the issue, I walked out of the dealership. This experience sums up how important a good customer experience is to me as a consumer. Had they upheld their initial agreement, they would have gotten my business. Instead, not only did they lose a sale, but they also lost the potential for a loyal customer. Ultimately, I was able to get the same deal from the dealer down the street I had purchased my last four cars from. In retrospect, I should have gone to them first due to my past positive customer experience with them. There are some very basic principles to enhance the overall customer experience. Following these guidelines will help earn repeat business and referrals! • P  ut yourself in the shoes of your customer. • Be empathetic to the process. • E  ducate your customer and be consultative. • Care. Understand that this is a relationship-driven business and providing a good customer experience can help you stand out from your competition, leading to loyal, repeat customers. GARRETT JOREWICZ IS THE REGIONAL DIRECTOR OF NEXTGEAR CAPITAL, INC.

DEALER NEWS

NJ_0614.indd 12

J U N E / J U LY 2 0 1 4

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:55 AM


NJ_0614.indd 13

5/19/14 4:12 PM


PRODUCTS

& SERVICES

Buying a Used Car NEW TECHNOLOGY TO AVOID CARS THAT HAVE BEEN WRECKED Buying a used car is almost always a roll of the dice. People have said, “You are just buying someone else’s problems.” The truth is there are plenty of good used cars out there. Most cars reach the used car market because of expiring leases or simply because owners are getting something newer, but there are exceptions. Some used cars are unloaded by their owners because of a problematic past. When considering a used car, we always recommend getting it inspected by a qualified mechanic and obtaining a vehicle history report from an agency such as Carfax.com or AutoCheck.com.

14

Unreported Damage Even taking these precautions is not guaranteed to uncover a vehicle’s every accident, however. Without taking a car apart, even an accomplished mechanic can miss signs of accident repairs. Moreover, vehicle histories only contain reported accident information. If an owner crashes his car into a

tree, manages to get his car to a repair facility without alerting law enforcement and doesn’t file an insurance claim to fix the damage, the accident probably won’t show up in a vehicle history report. So, is there a foolproof method for identifying cars that have been in unreported accidents and evaluating the extent of any resulting damage? Yes, and it’s currently being used by accident investigators and law enforcement to aid in reconstructing accidents. Not Exactly a Black Box Since 2010, most new cars are equipped with an event data recorder. Although it has very little in common with the black box we hear so much about after a plane crash, that’s the term most people understand when talking about the EDR. An airplane’s black box continuously records data – often including sound – while the plane is in operation, but the EDR is more of a snapshot of a car’s data from a few

REGULATORY NEWS

seconds before an accident to a few seconds after. During the course of an accident investigation, investigators use the crash data retrieval tool to download EDR data to determine what the car was doing in the seconds leading up to the crash. Was it speeding, swerving or braking? Was there an airbag deployment? Were the occupants wearing seat belts? CDR is also able to access other components that store data, such as the powertrain module, rollover sensor and airbag control module. The ACM is a virtual storehouse of crash data gathered through crashsensing systems such as seatbelt related sensors and occupant detection systems. So, What Does It Mean? How might all of this translate into helping the typical shopper avoid damaged vehicles when buying a used car? When purchasing a used car for resale, the used car dealer can make a CDR report part of the evaluation process. By

BY RUSS HEAPS plugging the CDR tool into the vehicle’s universal data port, the user can have a printed report in three or four minutes. This can happen at the dealer’s lot before accepting a used car as a trade-in, or at auctions, where dealers acquire 80 percent of the used cars they sell. Once they’ve won the bid on a vehicle at an auction, dealers have opportunity to inspect it before any money changes hands. If the CDR report uncovers a serious event, the dealer can opt out of the deal. So far, used car dealers haven’t embraced CDR as a sales tool, but the day may come when used car shoppers demand a CDR report just as they do service history records and vehicle history reports. RUSS HEAPS BEGAN COVERING THE AUTOMOTIVE INDUSTRY IN 1986. HE HAS SERVED AS MANAGING EDITOR OF AMI AUTO WEEK AND NOPI STREET PERFORMANCE COMPACT MAGAZINES. RUSS CURRENTLY FREELANCES HIS AUTO REVIEWS AND INDUSTRY ANALYSIS TO THE WASHINGTON TIMES, HISPANIC MAGAZINE, JOURNAL-REGISTER NEWSPAPERS, BANKRATE.COM, MYCARDATA. COM, INTEREST.COM, AND OTHERS. HE RESIDES IN GREENVILLE, SC.

AUCTION NEWS

Manheim Pennsylvania Honored CFPB Names New Regulator to Oversee for Energy Efficient Parking Facility Auto Finance ONE OF TWELVE LEADERS RECOGNIZED BY LEEP

JEFFREY LANGER TAKES LEAD

The Consumer Financial Protection Bureau has tapped a replacement regulator whose main jurisdiction is the auto finance market. Jeffrey Langer, who most recently served as senior counsel at Macy’s in Mason, Ohio, joined the CFPB as the assistant director of installment and liquidity lending markets in the bureau’s research, markets and regulations division. Langer also has served as a partner in several law firms, including Jones Day and Dreher Langer & Tomkies. He is a founding fellow and treasurer of the American College of Consumer Financial Services Lawyers and is a former chair of the Consumer Financial Services Committee of the American Bar Association Business Law Section. Langer’s appointment to the CFPB post was one of three recent hires. Christopher Carroll also joined the CFPB as the assistant director and chief economist for the office of research in the bureau’s research, markets, and regulations division. The bureau also announced Daniel Dodd-Ramirez joined the agency as the assistant director of financial empowerment in the bureau’s consumer education and engagement division. “I’m pleased that these incredibly talented individuals have joined the bureau,” CFPB director Richard Cordray said. “All three offices play an essential role in making sure that consumers are being treated fairly. These experts will lead the teams that help us monitor the marketplace and provide tangible benefit to consumers.” DEALER NEWS

NJ_0614.indd 14

J U N E / J U LY 2 0 1 4

As part of the U.S. Energy Department’s commitment to helping U.S. businesses save money by saving energy, the department’s Better Buildings Alliance is supporting the Lighting Energy Efficiency in Parking Campaign. More than 100 U.S. businesses and organizations have participated in the campaign and plan to or have already installed energy efficient lighting in their parking lots and garages, including Manheim Pennsylvania. On April 15, the Energy Department joined LEEP to recognize 12 organizations that are leading the way in efficient parking lot and parking garage lighting. Manheim Pennsylvania Vice President and General Manager Julie Picard accepted the “Highest Absolute Annual Energy Savings in a Retrofit at a Single Parking Area” award given to Cox Enterprises for the Manheim Pennsylvania project. As a Cox Enterprises subsidiary, Manheim participates in the company’s national sustainability program that focuses on waste management and reducing energy and water consumption. In the spirit of Manheim’s dedication to saving energy, Manheim Pennsylvania decreased the energy use in its 13,500,000

FROM LEFT: KEITH MASK, AVP FOR ENVIRONMENTAL SUSTAINABILITY, COX ENTERPRISES; JULIE PICARD, MANHEIM PENNSYLVANIA VICE PRESIDENT AND GENERAL MANAGER AND HUIET JOSEPH, SENIOR MANAGER OF ENERGY CONSERVATION, COX ENTERPRISES.

square foot parking lot by switching to reduced wattage lamps and a wireless control system. This new project caused the auction to cut its energy use by 50 percent or 1,761,687 kWh. The non-profit LEEP Campaign is a recognition and guidance program designed to encourage facility owners and managers to take advantage of savings opportunities from high efficient lighting solutions in their parking facilities. This effort is a collaboration between the Building Owners and Managers Association International, the Green Parking Council and the International Facility Management Association. W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:09 AM


NJ_0614.indd 15

5/19/14 4:12 PM


WASHINGTON

UPDATE

NIADA Government Report HERE’S A RUNDOWN OF SOME OF THE LATEST GOVERNMENTAL ISSUES AND ACTIVITY AFFECTING THE USED CAR INDUSTRY FROM NIADA REGULATORY COUNSEL SHAUN PETERSEN AND NIADA LOBBYIST SANTE ESPOSITO. National Independent Automobile Dealers Association

16

LEGISLATIVE REPORT H.R. 749, Eliminate Privacy Notice Confusion Act; S. 635, Privacy Notice Modernization Act of 2013 NIADA has been monitoring these bills, which would eliminate a costly and duplicative requirement of the Gramm-Leach-Bliley Act that all financial institutions mail their customers a copy of their privacy notice each year even if there has been no change in the privacy policy. While NIADA supports both bills in concept, our preference is the alreadypassed House bill because of concerns over an addition included in the pending Senate bill. Both would remove the annual privacy notice requirement if an institution has not changed its privacy policies or procedures. The bills do not exempt any institution from an initial privacy notice, nor do they allow a loophole for an institution to avoid issuing an updated notice. The Senate bill adds a qualifying

DEALER NEWS

NJ_0614.indd 16

J U N E / J U LY 2 0 1 4

condition for exemption – that customers be provided “access to such most recent disclosure in electronic or other form permitted by regulations prescribed under section 504.” The Senate bill envisions financial institutions posting their privacy policy on their website or transmitting it via email. While that might work for traditional financial institutions, some small dealers do not have websites, and email transmittals can be costly, cumbersome and speculative at best. And email transmittal assumes customers have the capability to receive them, which is not always the case. In addition, the reference to “section 504” creates significant uncertainty – that section, in part, gives the Consumer Financial Protection Bureau and Federal Trade Commission broad authority to issue regulations on an ongoing basis, leaving in doubt what “other form permitted by regulations” might take.

Because of that, NIADA’s position is that subparagraph (3) not be included in the final version of S. 635. On April 23, we met with staff of the House and Senate Banking Committee to discuss the bills, expressing NIADA’s support and raising questions about the Senate’s “add-on language,” and submitted a formal comment letter. MAP-21 Reauthorization The Moving Ahead for Progress in the 21st Century Act (MAP-21), a transportation bill enacted in 2012, expires Sept. 30. While Congress and the industry realize transportation bills are rarely passed on time and short-term policy extensions are usually required, this time extending the authorizing language will not be enough because the Highway Trust Fund will not have the funds to pay for the extensions. Congress must decide not only what policy provisions to include in the next

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 4:12 PM


NIADA Washington Update National Independent Automobile Dealers Association

reauthorization bill, but how to fund it. There is strong support from the industry for a gas tax increase from stakeholders who might be expected to oppose it, such as the American Trucking Associations and the U.S. Chamber of Commerce, but Congress does not appear to have the will to take on such a politically charged issue prior to the November mid-term elections. As a result, Congress will have to pass a short-term funding bill before its August recess. It’s estimated that $10 billion is needed through the end of the year, on top of the $53 billion already transferred from the general fund over the past few years. That’s a problem because the committees charged with drafting MAP21 reauthorization bills and short-term extensions do not have authority to add revenue to the trust fund. The committees that do have not indicated how or when they will deal with the situation. Meanwhile, Transportation Secretary Anthony Foxx unveiled the President’s longterm transportation bill, the Grow America Act, a four-year surface transportation reauthorization bill that includes more than $300 billion for highway repair and construction, public transportation, railroads and a multi-modal freight program.

W W W. N E W J E R S E Y I A D A . O R G

NJ_0614.indd 17

REGULATORY REPORT Consumer Financial Protection Bureau BMO Harris to pay flat fee: In response to the CFPB’s scrutiny over dealer markup in indirect lending, Chicago-based BMO Harris Bank announced it will pay dealers a flat percentage of the loan as compensation and eliminate dealer markup. CFPB director Richard Cordray applauded the move. Arbitration study: The CFPB is charged with studying the impact of arbitration clauses in consumer financial transactions. The study’s director indicated the bureau is looking at the outcomes of lawsuits involving consumer financial products (including class actions) and arbitrations, the costs and benefits to consumers of class actions, the impact of class actions and arbitrations on prices for goods and services, and the relationship between private and public enforcement of consumer financial services laws. The study is scheduled to be completed

Q

by the end of the year. FEDERAL TRADE COMMISSION Review of Fuel Economy Guide: The FTC is seeking comments on potential updates to Environmental Protection Agency fuel economy labeling rules. The FTC is updating the “miles per gallon” rating system and including a measurement for alternative fuel vehicles. The FTC is asking for industry input on useful information that is helpful to consumers and helps marketers avoid unfair and deceptive claims. New FTC commissioner: On April 28, Terrell McSweeny began her term as FTC commissioner, which ends in September. McSweeny previously served as chief counsel for competition policy and intergovernmental relations for the Department of Justice. She has served as a policy advisor to President Obama and Vice President Joe Biden.

There is strong support from the industry for a gas tax increase from stakeholders who might be expected to oppose it, such as the American Trucking Associations and the U.S. Chamber of Commerce, but Congress does not appear to have the will to take on such a politically charged issue prior to the November mid-term elections. 17

J U N E / J U LY 2 0 1 4

DEALER NEWS

5/19/14 11:10 AM


PRODUCTS

& SERVICES

Carfax Adds Vehicle History Search UNIQUE VEHICLE LISTINGS SITE HELPS CONSUMERS FIND THE RIGHT CAR WITH THE RIGHT HISTORY FROM DEALERS Carfax has unveiled a new online car shopping tool that helps consumers find the right car with the right history. At carfax.com, online shoppers now can search for used cars with specific vehicle history details – such as no accidents reported to Carfax, service records and Carfax 1-Owner. Used cars for sale from thousands of dealers on the new listings site all come with free Carfax vehicle history reports. Plus, vehicles are shown based on the history attributes shoppers want, making the shopping process for carfax. com visitors easier and faster.

18

“I found a great car on Carfax,” said used car shopper Nathan Walker from Washington. “I called the dealer immediately and he said the car was not listed in their inventory yet because it was still in detail and undergoing inspection. I already knew from the information in the Carfax listing that I wanted to see it. I drove forty miles to the dealership and bought the car.” Key vehicle history details seen in every vehicle listing help save time while sifting through search results. At carfax.com, visitors begin their search of more than one million used cars by selecting the vehicle history attributes they want. Listings from Carfax Advantage Dealers also include price, photos and a detailed description of the vehicle. Once potential buyers find the car they want, they easily connect with the dealer directly from the vehicle listing. “We’ve made sure our inventory is included on carfax.com for years,” said Jeff Best, vice president of used cars for Brown’s Car Stores. “It’s an easy way for us to get in front of readyto-buy shoppers. Consumers trust Carfax, which helps build their trust in the cars we list on Carfax.”

DEALER NEWS

NJ_0614.indd 18

J U N E / J U LY 2 0 1 4

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:10 AM


NJ_0614.indd 19

5/19/14 11:10 AM


MANAGEMENT

MATTERS

How to Present Products

ESTABLISHING A CONNECTION FOR RETENTION

20

Business managers tell me that 50 percent of their customers are paying cash. Deals are closed over the telephone and over the Internet. While the Internet has leveled the playing field, and many of today’s customers are not interested in taking test drives prior to purchasing, I find many of the traditional steps on the pathway to a sale have been shortened or eliminated altogether. In many cases the process has been shortened to simply lowering the price and hoping that the quoted price is lower than the competitors. The sales associate or sales manager simply provides the customer with the “out the door price” and sets a delivery date and time. The file might go to the business manager; it might also stay with the sales manager until the time of delivery. When price becomes the only selling point, the customer is cheated out of learning the value of the dealership and the goods and services it provides. For instance, where are your vehicles serviced? Do they go through a 17 or greater point check? Does your shop do more than smog and safety? If you do more than the minimum reconditioning for your inventory, your sales process should tell the story about how you go the extra mile to ensure customer satisfaction. You may ask, “What does the method of payment have to do with my future business relationship with the customer?” History has shown that a dealership can build customer retention by arranging financing for the retail sales. The customer completes all the loan documents at the dealership. When the customer wants to upgrade or trade in the vehicle, he or she assumes the dealership knows the payoff. The customer purchased the vehicle from the dealership and the customer who knows you, likes you and trusts you will return to you when he or she wishes to upgrade or trade because you know the true value of the vehicle. Additionally, each time the customer writes a check or enters the payment in a register, the customer is thinking about the dealership and the buying experience. If the customer pays cash, they only think about the dealership when they make the purchase or when the vehicle suffers a mechanical breakdown and they are in the shop, most likely without a service contract. Which is the more positive memory? How many of your current remote customers purchase service contracts? My guess is not many, because they were given the “Out the Door” sales figures and came to the dealership with a cashiers check made DEALER NEWS

NJ_0614.indd 20

J U N E / J U LY 2 0 1 4

u When

price becomes the only selling point, the customer is cheated out of learning the value of the dealership and the goods and services it provides.

out to the penny, because they secured financing elsewhere. Some customers still believe they can get a better deal if they pay cash to the dealership. The sales personnel think the deals are processed quicker, and they get paid faster if the customer pays cash for the purchase. My question is this: Is this truly the best way for a customer to pay for a vehicle? “Cash to you” is code that it is coming from another financing source. A customer with complete sales figures in hand is now a finance shopper. They will go to their own financial resources to inquire about financing. When they do go into a credit union they will most likely be introduced to an auto broker who will review your sales figures and trade market value. Have you ever had to renegotiate the sales figures just to hold the deal together after the customer has received sale counseling from an outside lender?

What can be done to effectively deal with the “remote buyer?” Word Tracks for the Remote Customer Situation: The deal was closed either over the Internet or telephone. The customer is only coming to the dealership on the day of delivery. Challenge: How to do a “financial” presentation when the customer is not in front of the business manager. Available tools: Internet, telephone, US Postal Service, GoToMeeting The deal information should be given to the business manager as soon as possible, just as if the customer were there at the dealership. Time is of the essence. If the deal was closed over the telephone the sales person should have completed a professional handoff to the business manager. EXAMPLE: The salesperson: “Thank you Mr. W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:10 AM


to the Remote Buyer

Customer for your business. We truly do appreciate it. If I may have just one more minute of your time today, I would like to introduce you to our business manager, who will be instrumental in completing your documentation of the sale. I will place you on hold while I get the manager on the line.” (For those that have a three way calling system, place the customer on hold and get the business manager on the line. If the business manager is busy with a customer then get the assistant business manager or sales manager on the line.) Once all parties are connected, set up for success. The salesperson should introduce the business manager: “Mr. Customer I have Manager on the line with us. Manager, Mr. Customer just purchased a ________________ from us and is asking for __________________ as a delivery date. I will get the documentation to you as quickly as possible. Mr. Customer I would like you to meet Manager, one of our business managers, who will be completing the documentation of the sale. Thank you Mr. Customer again for the purchase.” The sales person should hang up and the other two should be remaining on the line. Business manager: “Mr. Customer, when I get your documentation from the sales representative I will review the documentation and will be able to see what needs to be done. I would like to send you an email with some links about some opportunities you have to protect your new vehicle. After I review the file, I will need to spend about 10 to 15 minutes on the telephone with you. What is the best method of contact for you? When can we spend those

few minutes on the telephone?” (Keep in mind, the customer might be at work, they might be driving, they might say call me right back. The key is finding out when they will have 15 minutes to share with you that they will be near a computer. The business manager should send the new customer an email with links to information about your first visit products and services.) SAMPLE OF EMAIL: Dear Mr./Mrs. Customer, Thank you once again for your purchase. We are looking forward to getting your _________________ ready for delivery and the documentation completed. Please allow about one hour for the delivery process on the day that you are scheduled. At that time you will receive any remaining factory warranty information for your vehicle. As you know, factory warranties are limited to manufacturer’s defects in materials and workmanship. They do not cover everything. Based upon the current year and mileage, your vehicle qualifies for an added parts and labor agreement. I have attached a PDF file for your review. Many of our customers have asked us how they can cut down on the time it takes to clean their vehicles in addition to protecting it from fading and further oxidation. The solution is to have us apply our protective coatings to the exterior and interior of the vehicle prior to delivery. The protection comes with a ___ year guarantee against fading and makes clean up easier, resulting in a nicer looking vehicle that retains a high resale value. I have included the following links for you to review.

BY JAN KELLY (Please add the links to your website or product websites.) What time would be convenient for you to share about 10 to 15 minutes on the telephone? I look forward to talking with you soon. Thanks a lot, Business Manager Dealership Location Contact info The value of the professional hand off is for the customer to know from the sales department that there is a next step. The next step is our business manager, who will be in further contact with the customer prior to delivery. The value of the email is to provide information to the customer to get them thinking about how to protect their purchase. Please note: 55 percent of all communication is non-verbal, so customers need something they can see while you are talking with them over the telephone. Thirtyeight percent of all communication is how we hear the information, 7 percent is actual facts.

21

“GoToMeeting” venue: If you have access to GoToMeeting, you can simply make an appointment with the customer for a web meeting with the business manager. Using this tool the business manager can invite the customer to a meeting and the visual is on both the business manager’s and customer’s computer screens. If the computers have cameras, the business manager and customer can establish a virtual line of sight between all parties. Establishing a line of sight is always a plus. You will need to use the tools that are available to establish the connection with the customer prior to the delivery date. A customer with the out the door figures prior to delivery will shop for financing and will arrive at the dealership with a check for the balance. He or she may even shop for service contracts online prior to delivery. As we all know, no one can take better care of a customer than the dealership! The F&I products and services are the tools that allow the dealership to build customer retention and customer satisfaction. PRESIDENT OF KELLY ENTERPRISES, JAN IS AN EDUCATOR AND CONSULTANT, CONVENTION SPEAKER AND WRITES FREQUENTLY FOR INDUSTRY PUBLICATIONS. FOR INFORMATION ABOUT EDUCATIONAL VENUES, CALL 800.336.4275 OR VISIT JLKELLY.COM.

W W W. N E W J E R S E Y I A D A . O R G

NJ_0614.indd 21

J U N E / J U LY 2 0 1 4

DEALER NEWS

5/19/14 11:10 AM


COMPLIANCE

OVERDRIVE

How a Compliance Management System Can Help Your Dealership CONFIDENTLY MANAGE AND MAINTAIN YOUR DEALERSHIP’S COMPLIANCE

22

Independent automobile dealers work in a unique environment where employees often have to wear many different hats and juggle a variety of responsibilities. With all the moving pieces, it is not uncommon for dealers to be challenged with operational or compliance risk on a day-to-day basis. Many dealerships lack the size and/or staff to establish the proper checks and balances needed to uncover any compliance breakdowns. Additionally, the Consumer Financial Protection Bureau and other federal regulators now want dealers to demonstrate how they will ensure compliance with the various consumer protection requirements. With all of this intense focus on fair consumer treatment, a customer complaint could be potentially devastating to your dealership, sparking added regulatory scrutiny to an already rigorous process. Although dealers are exempt from formal CFPB oversight, any improper decisions made by dealerships do not absolve their lenders of responsibility for the resulting compliance or fair lending violations. In the interest of protecting and maintaining those relationships, it may be wise for dealers to follow the CFPB’s guidance on these matters. To offset compliance or customer service issues, a robust and effective compliance management system should be an essential part of any well-run dealership. While regulators have long considered the concept of a Compliance Management System to be the standard framework for financial institutions, it is not often part of a dealership’s compliance program. But, as the regulatory landscape becomes more and more complex, adapting CMS to meet the needs of dealerships may make all the difference when it comes to meeting the evolving demands of federal and state regulators. Implementing a compliance management system will help your dealership address compliance requirements and help organize your response to regulator inquiries. Equally important is that it will help address your lenders’ compliance needs and concerns. Adapting CMS to Your Dealership The CFPB has also adopted the CMS concept, with some modification, as part of its supervisory approach for banks and nonbanks under their jurisdiction. Additionally, the CFPB has made it clear, dating back to the first release of its examination manual, that a robust CMS must be at the core of an organization’s compliance efforts. While a full-on compliance management DEALER NEWS

NJ_0614.indd 22

J U N E / J U LY 2 0 1 4

system may be beyond the scope of what is financially and practically feasible for a dealership, the concepts behind CMS may benefit dealers as they struggle to stay current with numerous regulations. Implementing a CMS model can help ensure that the dealership’s policies and procedures remain in compliance with all federal and state consumer protection laws. An effective CMS establishes compliance responsibilities; communicates those responsibilities to the dealer’s employees and incorporates them into internal business processes responsibilities; ensures those responsibilities are carried out and regulatory requirements are met through frequent reviews and compliance audits; and enables and implements corrective action. Using CMS, dealers should initiate a cradle-to-grave approach, meaning they must monitor compliance from their initial advertising/marketing programs through post-closing collection processes. CMS should be integrated into the dealership’s overall framework and applied to its entire operations. Ultimately, compliance management should be a part of the daily routine of management as well as employees. An effective CMS will include components that address the following: Advertising and Marketing Promotions Dealership business is driven largely by advertising and marketing promotions, so dealers must exercise particular caution to avoid potentially unfair or deceptive acts or practices. A dealer must thoroughly review all advertisements and promotional materials to ensure that they fairly and adequately describe the terms, benefits and material limitations of the product or service being offered and that the special promotions or terms described in the advertisements are either available to all customers or very carefully and specifically identify the limitations of the offer. Dealer Rate Mark Ups In March 2013, the CFPB released a bulletin outlining its intent to hold indirect auto lenders responsible for compliance with fair lending requirements of the Equal Credit Opportunity Act related to dealer interest rate mark ups, participation and reserves. Although the CFPB did not altogether ban the practice of dealer mark ups, it did recommend lenders consider fairly compensating dealers using alternative methods, such as a flat fee per transaction, that do not result in discrimination

disparities. While it is unlikely that dealer mark ups will be entirely abandoned, a sound CMS will provide for having written policies in place outlining the circumstances that warrant pricing markups and how they will be consistently applied throughout the dealership. Disclosures State and federal law requires dealers to give consumers several written disclosures. These may include disclosures for the consumer’s rights concerning state lemon laws. A Buyer’s Guide disclosing warranty and defect information must also be posted on the windows of all used vehicles and given to the buyer. Additionally, consumers must be informed at the time of purchase that they are signing a legal contract and the possible ramifications. A CMS will help ensure the dealership is providing consumers with the required state and federal disclosures. It will also help ensure that the dealership has a process for identifying and implementing changes to required disclosures and any new disclosure requirements. Credit Application Process Make sure the credit application includes a disclosure informing the signing customer his or her credit report will be accessed and the information can be used to collect debt. Additionally, dealers must tell applicants their credit information sources and give the consumer a chance to notify the sources about any data he or she considers erroneous. CMS will guide a dealership in paying strict adherence to fair lending rules and privacy laws that apply to the credit application process. With increased regulatory oversight, compliance management activities should be a priority of every dealership. Therefore, implementing a CMS approach — even on a smaller scale — will help ensure that new laws and regulations are being embedded within a dealership’s business operations, while protecting the dealership from potential violations. A more formal, written policy and process for tracking and implementing compliance requirements will help your dealership manage and maintain its compliance. It will also give you, your lenders and regulators more confidence in your compliance programs.

BY CHIP ZYVOLOSKI

CHIP ZYVOLOSKI IS A SENIOR ATTORNEY FOR INDIRECT LENDING AT WOLTERS KLUWER FINANCIAL SERVICES. FOR MORE INFORMATION, VISIT WWW.WOLTERSKLUWERFS.COM/INDIRECT.

W W W. N E W J E R S E Y I A D A . O R G

5/19/14 11:10 AM


NJ_0614.indd 23

5/19/14 11:10 AM


NJ_0614.indd 24

5/19/14 11:10 AM


NJ 0614