Randy joined me for the 3rd of 3 sessions discussing some intricate points that he, as a California dealership, is accountable for to state and federal regulatory agencies. This is a session that may have some of you who are not in a role where these compliance items are part of your day to day, let's say... it may have you sort of "glaze over!" But, if you aspire to be in a management role at a dealership or you are today, listen up - the level of onerousness that compliance has come to in some states (and likely many more/all over time) is high. If you plan to play in the sell fun powersports or RV business you'll want to bookmark the 3 Randy Felice episodes for a later reflection. 

As mentioned at least once, Randy is not a lawyer. I also, am not a lawyer. We are having this discussion to show how immense the expectations are on you as a dealership, thru the perspective of a motorcycle dealership (Randy's) operating in California. 

Randy has graciously offered up his email to answer questions directly about any of these topics:

[email protected]

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Some notes from the session:

A culture of compliance in the sales department

Advertising

https://www.paa.org/Files/NADAAdGuide.pdf

Use your manufacturers verbiage only for rates and payment

Nothing is "free" when required to purchase something ...it's "included"

Illegal lotteries

Properly advertising rebates

Bait and switch

Bird dogging

Certified pre-owned (CPO) should not look like or imply from manufacturer unless it is

Fuel economy claims

Pricing, fees

Hang tags

Sales Contract Law

Military lending act - no gap

OFAC Office of Foreign Assets Control

10,000 cash form

Liability insurance if required in your state.

Privacy notice

Statement of how a vehicle left your property, if no license

How you state license and registration

Offering all back end products to all customers

Customer incentive acknowledgement

Correct application of rebates

Having a rate participation procedure so that there is no discrimination in how you mark up

rate nada process https://www.nada.org/faircredit/

Accept application from anyone who wants to apply

Adverse action form if turned down or not rate expecting.

Out of state sales license and sales tax

Customer information security

Recently dealership in CA was fined over 100,000

$3500 per sheet of paper left out, income, drivers license, social... just to be careful protect everything.

Lock up servers

Screen savers with passwords

Do not write down credit card info

Safes near desks

sales deals locked up,

need to know access,

password security,

drop box or fax machine secure information transfer, careful use of email

Random desk inspections

Red flag laws... identity theft purchasing bikes

The ITPP Compliance Officer is responsible for and has been assigned specific responsibility

for oversight, development, implementation, administration, and approval of material changes to

the Dealership’s Identity Theft Prevention Program (“ITPP”)

Credit applications through secure source, do not fill for the customer, must have DL before submitting.

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