Front Row. The. Convention 2014 INSIDE: Summer Washington State Independent Auto Dealers Association

Transcription

1 The Front Row Summer 2014 Washington State Independent uto Dealers ssociation Convention 2014 INSIDE: 9 Dealerships ccused of Deceptive dvertising by FTC Tire Pressure Monitoring Systems TCP & utomated Calls or Texts Class ction v. Small W Dealer The Lemon Law & Used Cars Christophe Villedieu Dreamstime Stock Photos Please visit us at:

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3 oard of Directors Summer2014 Inside Pg.3-9 Dealerships ccused of Deceptive dvertising by FTC Pg.5 - Tire Pressure Monitoring Systems ND TCP & utomated Calls or Texts Pg.6 - Class ction v. Small W Dealer Pg.7 - The Lemon Law & Used Cars Pg.8 - Social Media 101: The asics Pg.10 - Liability for Vehicles That Fail Out-of- State Inspections Pg.11 - dministrative ction Pg.12 - Quality You Can Count On Pg.14 - Read & Respond Randy Fletcher President & uto Dave Randall Secretary Randall s uto Sales Mo liabadi Chairman South Tacoma uto ob Reid Vice President Reid & Johnson Motors J.T. Curry Treasurer Motors Northwest Emil Scarsella Chairman Town & Country uto Sales 707 uburn Way South uburn, W (253) (253) DISCLIMER: please be advised that the information contained in this newsletter is, to the best of our knowledge, current and correct. However, we caustion our membership not to use this publication as the final authority. It s purpose is to be a guide. The Front Row is a publication of the Washington State Independent utomobile Dealers ssociation (WSID). WSID is a chartered non-profit orginization in Washington. The association was established in 1953 and is affiliated with the National Independent utomobile Dealers ssociationin rlington, Texas. The statements and opinions expressed herein are those of the individual authors, or its publisher. ny legal advice should be regarded as general information. It is strongly recommended that one contact an attorney for counsel regarding specific circumstances. Likewise, the appearance of advertisers or their identification as members of WSID, does not constitute an endorsement of the products or services featured.

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5 Summer Dealerships ccused of Deceptive dvertising by FTC The Federal Trade Commission announced that nine auto dealers, including stores in California, Georgia, Illinois, North Carolina, Michigan, and Texas, have agreed to enter into consent orders to settle deceptive advertising charges. The FTC is also pursuing litigation against a tenth dealer. The complaints allege violations of the FTC ct, the Consumer Leasing ct (CL) and the Truth in Lending ct (TIL). The dealers are alleged to have made a variety of misrepresentations in print, internet, and video advertisements with numerous violations including: Deceptively advertising a specific low price that was unavailable. dvertising $0 up front to lease a vehicle when there were substantial fees and other amounts. Failing to disclose certain lease and credit related terms. dvertising a low monthly payment that was in actuality a teaser rate that would increase. Sending mailers suggesting consumers had won a sweepstakes prize when, in fact, they had not. The proposed consent orders prohibit the dealerships from misrepresenting the cost of leasing a vehicle, the cost of purchasing a vehicle with financing, or any other material fact about the price, sale, financing, or leasing of a vehicle in any advertisement. In several cases, the orders address the alleged TIL and CL violations by requiring the dealerships to clearly and conspicuously disclose required terms. In the case where the dealership allegedly misrepresented that consumers had won a prize, the proposed order also prohibits misrepresenting material terms of any prize, sweepstakes, giveaway, or other incentive. Remember to review all of your advertising to ensure it: Is not misleading; Includes all required disclosures if applicable; and That the disclosures are clear and conspicuous. Do not rely on advertising agencies or third parties to ensure compliance. They won t be paying the penalty for you if the g overnment comes after you. y: Kurt Strovink, JD 2 3

6 WSID Scholarship 2014 The amount of the scholarship will be determined by WSID, and will be awarded to the winning nominee with an outstanding high school record of achievement and evidence of excellent college aptitude. Eligiblity: a) be a high school senior, b) be the son, daughter or grandchild of an WSID member in good standing, c) possess an excellent high school record of academic achievement measured by your performance in valid secondary school courses including English, Mathematics, Physical Science and Social Sciences, d) demonstrate an aptitude for college work which will be measured by performance on college entrance exams, including the Scholastic ptitude Test (ST), if taken. Scholarship recipients will be announced ugust 9, 2014 at our annual convention. You will need to be present to accept your award. The scholarship will be funded upon notification of enrollment by the college. To pply Download Forms From OR Request Copy From info@wsiada.com

7 Tire Pressure Monitoring Systems Federal law prohibits manufacturers, distributors, dealers, and motor vehicle repair businesses from knowingly making inoperative, in whole or in part, any part of a device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. There are several important scenarios to consider. If a customer purchases a set of tires and wheels and declines to purchase new tire pressure monitoring systems (TPMS), the service provider may be in violation of federal law. y removing tires and wheels with functioning TPMS sensors and replacing them with tires and wheels without TPMS sensors, the service provider has knowingly removed an essential part of the TPMS. Likewise, if a service provider damages a sensor and does not replace it or if the customer directs the service provider to finish service without replacing the damaged part, the service provider would be in violation of federal law because it knowingly made inoperative a part of the device. This is the case even if the customer insists that the damaged part not be replaced or if the customer agrees to sign a waiver. Conversely, if the service provider has not knowingly made a device inoperative, then the service provider would be able to release the vehicle to the customer without violating federal law. Thus, the key factor is knowledge. y: Davies Pearson, P.C. Summer 2014 TCP & utomated Calls Or Texts If your dealership uses anything that may automate the process of dialing, sending a prerecorded message, sending a text message, or all of the above for a sales purpose look out! On October 16, 2013 a new consent standard took effect under the Telephone Consumer Protection ct (TCP). Complying with this new TCP consent standard is vital for all dealers who place sales calls. Customers can sue you individually or as part of a class for damages of $500 per call for negligent violations and up to $1,500 per call for willful or knowing violations. efore these new rules came down, all you needed to use such a system was prior express consent. Essentially, a customer was deemed to volunteer their consent whenever they volunteered their cell phone number, even if there was no disclosure to the customer about how their number would be used. The rationale was persons who knowingly release their phone numbers have in effect given their invitation or permission to be called at the number which they have given, absent instructions to the contrary. Sadly, this is no longer true. The new prior express written consent standard applies to any call that includes or introduces an advertisement or constitutes telemarketing using an automatic phone dialing system or an artificial or pre-recorded voice to, among other destinations, a cellular phone. It makes no difference whether or not the customer was actually charged for the call. Worse, a text message is now considered a call for purposes of the TCP. The new requirements are threefold: 1. The consent must: a) be in writing, b) bear the signature of the person called c) clearly authorize the seller to deliver or cause to be delivered to the person called advertisements or telemarketing messages using an automatic telephone dialing system or artificial prerecorded voice to the telephone number to which the signatory authorizes such advertisements or telemarketing messages to be delivered. 2. Dealers must not require consumers to provide consent in order to proceed with a purchase. 3. The disclosure must be clear and conspicuous. a) disclosure should be apparent to a reasonable consumer, separate and distinguishable from the advertising copy or other disclosures. Not in boilerplate text! If you rely on 3rd party lead generating services, pay particular attention. Consent is specific to each particular seller. Thus, the consent should identify the seller obtaining the consent. For example, consent to be called by XYZ utos is not sufficient consent for XYZ Finance, even if they are owned by the same person. If a 3rd party lead company obtains consent and forwards leads to a dealer, in most cases, that consent will not identify the name of the dealer because the lead company cannot know the name of the dealer to whom they are referring the customer until the lead is submitted. y: Kurt Strovink, J.D. 4 5

8 Class ction v. Small W Dealer Summer 2014 The opportunities for dealerships to violate the Truth In Lending ct (TIL) are many and varied but every once in awhile I am surprised by a new and novel violation. Sadly, this new violation was discovered by an attorney who now has a pending class action lawsuit against a Washington dealer. Even worse, the dealer is a small dealer by almost anyone s standard, boasting perhaps 20 vehicles on the lot at any given time. While I feel for the dealership being sued, I would be remiss not to take this opportunity to discuss what gave rise to the claim so that you may avoid such lawsuits yourself. The issue is that TIL and Regulation Z specifically command that a creditor disclose: The number, amount, and due dates or period of payments scheduled to repay the total payments. (15 u.s.c. 1638(g)(6), and Regulation Z, 12 C.F.R IS(g)) Further, the official staff commentary to Regulation Z, provides: Section (g) requires creditors to disclose the timing of monthly payments. To meet this requirement, creditors may list all of the payment due dates. They also have the option of specifying the period of payments scheduled to repay the obligation. s a general rule, creditors that choose this option must disclose the payment the payment intervals or frequency, such as Monthly or i-weekly and the calendar date that the beginning payment is due. Now that you know what to be on the lookout for, see if you can 5 6 identify what is wrong with the following disclosure on a retail installment agreement: YOUR PYMENT SCHEDULE WILL E: Number of Payments: 36 mount of Payments: $ When Payments are Due:10/15/2012 Could you find the violation? You get a gold star if you guessed that the problem was a missing disclosure regarding the period of payments. Unless the dealer was providing a list of all the payment due dates, the above disclosure violates TIL. Clearly, it is not fair for a dealer to leave the period of payments to the imagination. Such a practice leaves the dealer able to argue that the payments were due weekly rather than monthly and therefore cause the customer to default on the loan. full disclosure should be as follows: YOUR PYMENT SCHEDULE WILL E: Number of Payments: 36 mount of Payments: $ When Payments are Due: Monthly beginning 10/15/2012 This dealer has technically violated TIL and the only question now is what the damages will be. The point to remember is you must never neglect to disclose the period of payments on your retail installment agreements unless you provide the customer with a list of all the payment due dates. The fine folks who create forms can only do so much in the form design. Even if you have the best form in the world, failing to complete the form accurately can expose you to significant liability. y: Kurt Strovink, JD

9 The Lemon Law & Used Cars Summer 2014 Too many consumers purchase used vehicles from an independent dealer, take issue with the quality of the vehicle, then threaten to sue the dealer for selling them a Lemon. In turn, WSID receives worried calls from dealers concerned that they may be taken to task for violation of the Lemon Law. These dealers concern is misguided as to the actual law being argued. Many consumers have heard of the Lemon Law and wrongfully argue that it applies in their instant case when, in fact, they are trying to articulate a breach of implied warranty claim. Washington state does have a Lemon Law, but it applies only to new vehicles and new vehicle dealers. new vehicle is one originally purchased new (or leased) by a consumer in Washington. The law does not cover trucks with gross vehicle weight ratings over 19,000 lbs, motorcycles with engine displacements of less than 750 cubic centimeters or vehicles purchased or leased by a business as part of a fleet of 10 or more. vehicle may qualify as a lemon if it has one or more substantial defects that have been subject to a reasonable number of attempts to diagnose or repair the problem(s) under the manufacturer s warranty. Substantial defects are those which are life threatening, create a risk of fire or explosion or which substantially impair the vehicle s reliability, resale value or safe use. The law does not cover problems caused by owner abuse or negligence, or any unauthorized modifications or alterations made to the vehicle. (See RCW ) WHT IS RESONLE NUMER OF REPIR TTEMPTS? reasonable number of attempts for most eligible vehicles when one or more of the following have occurred: Diagnosis or repair of the same serious safety defect has been attempted two or more times (with at least one during the eligibility period ) and the defect continues to exist; Diagnosis or repair of the same nonconformity has been attempted four or more times (with at least one during the warranty period ) and the defect continues to exist; vehicle has been out-of-service for diagnosis or repair of one or more nonconformities or serious safety defects (whether or not repaired) for a cumulative total of 30 calendar days, with at least 15 of those days occurring during the warranty period. Within a twelve-month period, two or more different serious safety defects, each of which have been subject to diagnosis or repair one or more times, where at least one attempt for each serious safety defect occurs during the period of coverage of the applicable manufacturer s written warranty and within the eligibility period. YOU HVE LEMON WHT SHOULD YOU DO? To start a Lemon Law claim you must send the manufacturer a written request to repurchase or replace your defective vehicle. fter receiving your written request to repurchase... you still have an affirmative obligation to let customers know when you are selling them a vehicle that was returned to the manufacturer as a Lemon. or replace your defective vehicle. fter receiving your written request to repurchase of replace, the manufacturer has 40 days to respond. Request for rbitration Form must be received by the Lemon Law dministration within 30 months of the vehicles original retail delivery date whether or not the 40 day reply period has expired. S DELER, MUST I DISCLOSE THT MY VEHICLE WS RETURNED TO THE MNUFCTURER S LEMON? Even though the Lemon Law does not apply to used vehicles, you still have an affirmative obligation to let customers know when you are selling them a vehicle that was returned to the manufacturer as a Lemon. WC section 2(h) specifies that Returned to Manufacturer is a brand. rands may seriously alter a vehicles value and therefore should be prominently and conspicuously disclosed in writing to all customers. One cannot merely pass off a vehicle that was returned to the manufacturer under the Lemon Law to a customer without informing them of the vehicle s status as a Lemon Law car. y: Kurt Strovink, JD 6 7

10 Summer 2014 Social media is a phrase that can strike fear into the hearts of auto dealers. The thought of having to post high engagement blurbs, monitor customer complaints and increase sales through appropriate social media channels can be challenging. s an independent auto dealer the key to success is separating your business from the rest. Social media will keep you ahead of the game and should be the online face of your business. You care about how customers view your store and their experience once they arrive, but are the same care and effort given to driving people to your dealership in the first place? Facebook Having a presence on Facebook can be crucial to your success. 23% of Facebook users check their account five or more times a day. 1 Clearly this indicates people are interested in what others are doing and where they are going, but more importantly, 47% of Facebook users claim that Facebook specifically impact their purchase behavior. Having a simple page with location, store hours and a place to ask questions will help steer people in your direction. 1 Facebook is also a prime place to experiment with calls to action, post giveaways, sale events, or community service projects. bove all, Facebook is also the easiest place to interact and respond to both customer complaints and compliments. The most attractive dealerships offer advice and politely respond to any review that gets posted no matter how difficult the customer was. Someone will always complain about one thing or another, the key is not to ignore it. The best response is to use the opportunity to repair the relationship and/or express compassion. Even a simple thank you under a compliment shows that personal touch that consumers crave when shopping. Some great examples can be seen on both NID s and LeMay Car Museum s Facebook pages. Twitter While not as popular as Facebook, Twitter can also help your dealership create connections to those interested in buying a car. few common phrases associated with Twitter are, tweeting, or writing a small 140 character post, retweeting, which means, sharing a another s person post, and twitpic, or posting a photo. You may also see a hashtag (#) before a phrase, which refers to an important topic or takes you to a place you would want to read more about. The (@) symbol before a name or page just refers to the username and you will need to use it when you refer to someone specifically for what a great chapter meeting! #WSIDTacomachapter, sends a publicly viewable message to WSI- D. Those that are subscribed to WSID will be able to see the post. Retweeting customers that give you a good review, posting links to videos or news articles that impact your business, or even posting pictures of your staff helps to communicate openness and personality. The downside of Twitter is that only 47% of Twitter users actively post. ccordingly, you need to find ways to engage people. 1 good start is to follow others. To follow means to subscribe to others updates. The more people or pages that show up the more material you have to relate back to your dealership and ultimately your brand. Pages that could be useful are auctions that you attend, automotive magazines, news stations or your local car association. SEO more practical reason for a social media presence is a higher ranking search engine ranking. Search engines are services like Google, Yahoo, or ing. Search engine optimization (SEO) is employed to make your website or online offerings display higher when others search for a topic of interest. Think of it as a phone book. Wouldn t you want to be at the top? When customers are searching for cars or a particular dealership, the bigger your dealership s web presence, the more likely it will be among the first to pop up in their search. Your Facebook and Twitter pages can do more for this optimization when added to s. s that have, for example a Facebook or Twitter, button included in the have 158% higher click through rate. 2 This means that more people open them, read them, and absorb their content. Pages that can catch an audience s attention will also help your SEO. dding videos and pictures will have the public repeatedly viewing your page. 2 This does not mean listing your entire inventory every couple of weeks, no one wants to see dubious amounts of stock. Posting one or two special or luxury vehicles a week would be appropriate. Think about what would interest you when looking for a car and tailor that vision to your pages. Social media is now essential in the way we communicate; as businesses we need to find a way to use this communication appropriately and positively. Show the world that you want their business. y: Jessica lauert 7 8 Social Media 101: The asics

11 Summer 2014 Resources Shocking New Social Media Statistics in merica. Convince and Convert. andconvert.com/the-socialhabit/11-shocking-new-social-me dia-statistics-in-america/ Think of what would interest you when looking for a car and tailor that vision to your pages Marketing Statistics that Will In fluence Decisions in Janu ary 7, cialmediatoday.com/brian na5mith/ /20-market ing-statistics-will-influence-deci sions Social Media Revolution. Erik Qualman. March 21, FYPQjYhv Examples of Excellent Customer Service on Facebook. Mark Hayes. pril 18, com/blog/ exam ples-of-excellent-customer-ser vice-on-facebook#axzz2wd8hu8vl

12 9 10 Summer 2014 Liability for vehicles that fail out-of-state inspections When selling used vehicles, what burden do you have to make certain that those vehicles pass inspection in the state where the buyer lives? recent case in Maryland illustrates one of many problems that can arise from sales to out-of-state residents. Joseph Ingram, a resident of Maryland, purchased a Mitsubishi Lancer over the internet from a New York dealer called uto Palace. The car was delivered to Ingram in Maryland. Ingram was soon enraged to discover that it would cost him approximately $ to bring the car into compliance with Maryland law. Ingram then asked uto Palace to cover the cost. uto Palace offered to repair the vehicle in-house or cancel the sale but refused to pay for the outside repair order. Ingram sued. Ingram alleged numerous things but the only claim worthy of discussion was violation of Maryland s Consumer Protection ct because uto Palace failed to disclose that the car would not pass Maryland s inspection. Oddly enough, Ingram presented no evidence whatsoever that he had actually inquired as to whether the car would pass inspection in Maryland and the court determined that uto Palace had no affirmative obligation to disclose that the vehicle would not pass Maryland s inspection. There was no evidence that uto Palace, a New York used car dealer, would have any knowledge of expertise regarding Maryland s inspection requirements, and it was unreasonable for a Maryland purchaser to assume that a vehicle from New York dealer would pass inspection in Maryland. ccordingly, Ingram lost the case and uto Palace won. However, it is worth considering that were circumstances a bit different, this case could have easily gone the other way. For example, had uto Get Covered Dealer Insurance Provided y People Who Understand Dealer Needs Erin Shepard-nthony Palace told Ingram that the car would pass Maryland s inspection, uto Palace would have been held to that standard. The moral of the story is: Make certain your staff knows not to go beyond mere sales talk to assertions of fact unless those facts are 100% accurate. Ingram v. uto Palace, Inc., 2012 U.S. Dist. LEXIS (D. Md. October 17, 2012). y: Kurt Strovink, JD Dealer onds from $200 oac WSID MEMER One Call is all it takes! Toll Free ShepQuote.com

13 Summer 2014 dministrative ction gainst Dealers March 2014 Tacoma Finding: Late title transfer. ction: Fined $100. McKenna Finding: Sold vehicles not meeting emissions standards. ction: Fined $500. Everett Finding: Failed to disclose rebuilt status of vehicles. ction: Fined $1,500. Lakewood Finding: Unlicensed dealer activity. ction: Cease and desist and fined $7,000. Walla Walla Finding: Late title transfers, failure to timely pay off lienholders of trade-in vehicles, sale of vehicles without possession of title, failure to pay previous penalty. ction: License revoked for 10 years, fined $19,000. urien Finding: Unlicensed dealer activity. ction: Cease and desist and fined $7,000. ellevue Finding: Failed to disclose rebuilt status of vehicles. ction: Fined $250. Seattle Finding: Retail sales without a retail license. ction: Fined $100. Vancouver Finding: Unlicensed dealer activity. ction: Cease and desist and fined $8,000. Puyallup Finding: Unlicensed dealer activity. ction: Cease and desist and fined $8,000. January 2014 Gig Harbor Finding: Unlicensed dealer activity. ction: Cease and desist and fined $13,000. The fine is stayed (not imposed) if there are no similar violations for 1 year. Everett Finding: Late title transfers. ction: Fined $1,000. Snohomish Finding: Sold vehicle not meeting emissions standards. ction: Fined $2,000. Woodinville Finding: Illegal use of transporter plates. ction: Revocation of license stayed pending no further violations. Puyallup Finding: Failed to disclose rebuilt status of vehicles. ction: $3,000 fine, $2,500 of which stayed (not imposed) if there are no further violations within 1 year. Wapato Finding: Unlicensed dealer activity. ction: Cease and desist and fined $5,000. December 2013 Renton Finding: Late title transfers. ction: Fined $3,250. Shoreline Finding: Place of business violations. ction: They agreed to be in compliance by November 22, Seattle Finding: Unlicensed dealer activity. ction: Ordered to cease and desist, and fined $6,000. The fine is stayed (not imposed) if there are no similar violations for 1 year. Renton Finding: dvertising violations for an unlicensed motor vehicle dealer subagency. ction: Fined $250. Gig Harbor Finding: Unlicensed dealer activity. ction: Ordered to cease and desist, and fined $5,500. Yakima Finding: Didn t have possession of a vehicle title at the time of sale. ction: Fined $500. Seattle Finding: Sold a vehicle without possessing the title. ction: Fined $

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16 Summer 2014 Washington State Independent uto Dealers ssociation Read & Response Summer If dealership personnel represents to a customer that a particular vehicle will pass another state s vehicle inspection, that vehicle must pass the inspection. True False 2. Dealerships in Washington are not required to verify that a particular vehicle will pass another state s vehicle inspection. (Choose the best answer.) C True False True, unless the dealer represents that the vehicle will pass another state s inspection. 3. Dealers who use automatic dialing systems for advertising purposes must have express, written and signed consent from the person they are calling. True False C True, but a customer who willfully provides their telephone number is assumed to have consented to receive calls. 4. utomated text messaging is permissible. C True False True, only if the dealer has express written and signed consent from the customer. 5.Dealers who use automated calls and/or text messages may be liable for up to $1500 per call or text. True False 6. When completing a Retail Installment greement, you must always disclose the period (frequency) of payments. C True False True, unless you provide the customer with a list of all payment due dates. 7. If you hire an advertising company to do your advertising, the company you hired will be liable if they make a mistake that results in your dealership being sued. True. The people you hired messed up so you have no liability. False. The dealership is primarily responsible for ensuring that all advertisements comply with the law. 8. y removing tires and wheels with functioning TPMS sensors and replacing them with tires and wheels without TPMS sensors, the service provider has knowingly removed an essential part of the TPMS and has therefore violated federal law. True False 13 14

17 Summer If a service provider damages a sensor and does not replace it or if the customer directs the service provider to finish service without replacing the damaged part, the service provider would be in violation of federal law because it knowingly made inoperative a part of the device. C True True, unless the customer signed a waiver False 10. The Washington state Lemon Law applies to new vehicles only. True False 11. If you have a vehicle that was returned to the manufacturer as a Lemon, you should notify any potential purchasers, in writing, on the purchase order. True False You may fax this quiz back to: Name: Dealership Name: Dealer Number: ddress: Phone Number: License Expiration: Visa: Mastercard Check Credit Card Number: Exp: Security Code: 14 15

18 Convention 2014 Michael Sommerville - Comedian Harmon rewery - eer lueprints Trio - Jazz Smokey Joes - Cigars Pat Cashman - Host Pacific Grill - Catering

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20 Washington State Independent uto Dealers ssociation Phone: Mailing address: P.O. ox 1837 uburn, W Location: 707 uburn Way South uburn, W Website: