Page 38 - Summer 2024
P. 38

Continued from page 36.

                                   Internal business review and compliance audits.


                                   After  implementing  lessons  learned  through  education,  continually  inspect  your
                                   operations to help ensure proper compliance. Ask questions such as the following:


                                                 •   Who  checks  your  dealership  advertising  against  the  FTC  rules
                                                     and compares it to prosecuted violations?
                                                 •   Who wrote your F&I process and sales training material? When
                                                     was the last time you reviewed them?
                                                 •   Are you possibly wittingly or unwittingly payment packing?
                                                 •   Are you possibly wittingly or unwittingly implying that F&I product
                                                     add-ons are mandatory?
                                                 •   Are you processing customer cancellations fairly and in a timely
                                                     manner?
                                                 •   Who  in  your  dealership  audits  your  compliance  process  and
                                                     compliance dashboards?

                                   As  always,  Brown  &  Brown  works  hard  to  help  dealerships  like  yours  sell  more
                                   units, maximize your business valuation, and keep your hard-earned gains through
                                   compliant business practices.


                                   If  you  have  questions  or  would  like  to  discuss  how  Brown  &  Brown  can  provide
                                   you with one-on-one personal service and support your needs in this dynamic and
                                   evolving regulatory environment, please contact our National Director of Compliance,
                                   Tom O’Neil, directly at 614-580-5110, or Tom.Oneil@BBrown.com.



                                   PLEASE NOTE:
                                   THIS DOCUMENT AND PRESENTATION ARE FOR INFORMATIONAL PURPOSES ONLY.
                                   THE PRESENTER IS NOT AN ATTORNEY AND IS NOT OFFERING LEGAL OPINION OR LEGAL ADVICE.
                                   NOTHING PRESENTED OR STATED SHOULD BE RELIED UPON AS LEGAL ADVICE OR ADVICE OF ANY KIND.
                                   Given the extremely dynamic and rapidly evolving regulatory and compliance landscape,
                                   comments and references do not take into account any applicable pending or future legislation.
                                   PLEASE CONSULT WITH YOUR LEGAL COUNSEL FOR MORE COMPLETE INFORMATION ON THIS TOPIC.
                                   DISCLAIMER: Brown & Brown, Inc. and all its affiliates, do not provide legal, regulatory or tax guidance,
                                   or advice. If legal advice counsel or representation is needed, the services of a legal professional should
                                   be sought. The information in this document is intended to provide a general overview of the topics and
                                   services contained herein. Brown & Brown, Inc. and all its affiliates, make no representation or warranty
                                   as to the accuracy or completeness of the document and undertakes no obligation to update or revise the
    38                             document based upon new information or future changes.


                                             1.   https://www.ftc.gov/news-events/news/press-releases/2024/01/ftc-pauses-cars-rule-effective-date
                                             2.   https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act
                                             3.   https://www.ftc.gov/business-guidance/resources/dealers-guide-used-car-rule
                                             4.   https://www.ftc.gov/news-events/news/press-releases/2014/01/ftc-announces-sweep-against-10-auto-
                                                 dealers
                                             5.   https://www.ftc.gov/news-events/news/press-releases/2024/01/ftc-connecticut-take-action-against-
                                                 manchester-city-nissan-deceiving-consumers-forcing-junk-fees
                                             6.   https://www.ftc.gov/system/files/ftc_gov/pdf/1-ComplaintbyFTC-WIagainstRhinelander.pdf
                                             7.   https://www.consumerfinance.gov/about-us/newsroom/cfpb-orders-toyota-motor-credit-to-pay-60-
                                                 million-for-illegal-lending-and-credit-reporting-misconduct/
        		www.maada.com
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