Front Row. The INSIDE: Spring Washington State Independent Auto Dealers Association

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1 The Front Row Spring 2014 Washington State Independent uto Dealers ssociation INSIDE: W Dealer Penalized $1,750,000 Copyright Violations & Disgruntled Employees CFPB & Dealer Rate Participation re You Liable for a Mechanic s Faulty Repair? The Used Car Rule and Private Lawsuits Trauma Care Fee - Explained Please visit us at:

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3 : Spring 2014 Board of Directors Inside Pg.2 - CFPB and Dealer Rate Participation Pg.3 - re you liable for a mechanic s faulty repair? Pg.4 - Washington Dealer Penalized $1,750, Pg.6 - Copyright Violations - Disgruntled Employees Pg.8 - Trauma Care Fee Explained Pg.9 - The Used Car Rule and Private Lawsuits Pg.10 - dministrative ction Pg Read & Respond Randy Fletcher President B & B uto Dave Randall Secretary Randall s uto Sales Mo liabadi Chairman South Tacoma uto Bob 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.

4 Spring 2014 CFPB and Dealer Rate Participation By Kurt Strovink, JD The Consumer Financial Protection Bureau (CFPB) is all the rage lately. They re hiring undercover investigators to mystery shop dealers and they are now actively investigating the propriety of dealers retaining a mark-up on the loans made to consumers. The CFPB is worried that the practice provides too much incentive for dealers to push car buyers toward a loan they can t afford and wants the industry to move toward a flat fee for loan origination. In an effort to stem the tide of dealer rate participation, the CFPB is asking financing sources to police dealers and ensure they are not discriminating against borrowers based on gender, race, national origin, or any other prohibited class. In fact, it was just announced that lly Financial, the former finance arm of GM that is now an independent bank, settled a case with the CFPB for $98 million dollars. The settlement provides $80 million in compensation for victims of past discrimination by one of the nation s largest auto lenders and requires lly to pay $18 million to the CFPB s Civil Penalty Fund. Vehicle industry organizations are engaged in ongoing discussions with the CFPB in an effort to add clarity for finance sources and dealers. There has been no official statement from CFPB on a solution, however one possible compromise has emerged from a 2007 Department of Justice Consent Order focused on the lending practices at two dealerships. Pursuant to the order: The dealership could continue participating in the loan rate (dealer markup), provided the markup was predetermined, charged to all customers, and did not exceed the lower of the finance source cap or: - 2.5% on contracts under 60 months. - 2% for contracts over 60 months. The dealership could lower (but not increase) the participation rate for good faith, competitive reasons consistent with the Equal Credit Opportunity ct (ECO) but, among other requirements, had to: - Document the reasons for each lowered rate. - Ensure documentation was reviewed by the general manager or designee. - Retain the documentation. - Conduct training. Under the order, acceptable reasons to lower a rate were limited to: The customer stated a monthly payment limit/constraint of $X per month. The customer stated she had access to an equal or more favorable rate from another dealer or lender. (must identify offer) The dealership offered special promotional financing to all customers on the same terms. The customer qualified for factory or other subvened (relieved/lowered) interest rate. The customer qualified for the dealership s Employee Incentive Program. Inventory considerations applied. (must specify) This is one possible outcome or strategy for a dealership documenting compliance with the ECO. Moving to a lending policy like the one outlined above is not mandatory, nor has the CFPB indicated that it would consider allowing it a safe harbor to avoid its concerns about auto finance. However, it is an example of a direction the CFPB may ask the industry to move. Dealerships should consult with their own counsel before making decisions on changing policies on customer finance options. 2

5 Spring 2014 re you liable for a mechanic s faulty repair? By Kurt Strovink, JD recent case from Illinois raises some troubling issues about recommending service providers to your customers. The facts of the case are fairly straightforward: Patricia Boatwright leased a 2007 Bentley Continental from Gold Coast Bentley. When the car started acting up, Ms. Boatwright asked the dealership where she should take the vehicle for repairs. The dealership recommended We ll Clean Car Wash ( We ll Clean ) for repair work. Ms. Boatright did in fact take the Bentley to We ll Clean for the repairs. Unfortunately, a We ll Clean employee took the Bentley out for a spin on a public road where it was damaged in an accident. Ms. Boatwright then sued the dealership (and everyone else involved) for negligence and fraud. licensed and certified to repair Bentley vehicles. The court found that it was reasonably foreseeable that failure to confirm licensing and authorization could result in damage to the Bentley, however damage caused by a vehicle accident was not reasonably foreseeable. Did you catch that? Ms. Boatwright lost on the issue of foreseeability because the car accident was not reasonably foreseeable. However, the dealership would have been held liable if We ll Clean performed faulty repairs. The moral of the story is make certain that whomever you are referring customers to has been properly vetted. It would be a good practice to create a list of authorized service providers for your employees and make certain that those service providers have the requisite license and authorization to perform the work requested. If you don t, you may find yourself liable for the faulty work done. Boatwright v. Neagu, 2012 Ill. pp. Unpub. LEXIS 999 (Ill. pp. May 2, 2012). The trial court dismissed every single one of Ms. Boatwright s claims. However, Ms. Boatwright appealed. The appellate court properly determined it was necessary for Ms. Boatwright to prove that the dealership owed a duty to her before the dealership could be held liable. When determining if a duty of reasonable care existed, the court considered the issue of foreseeability e.g. whether it was foreseeable that referring Ms. Boatwright to We ll Clean would result in injury to Ms. Boatwright or her property. Ms. Boatwright asserted that the dealer, as a Bentley dealership, was in the business of providing information about repair related to Bentley vehicles and that the dealer had failed to make certain that We ll Clean was properly Get Covered Dealer Insurance Provided By People Who Understand Dealer Needs Dealer Bonds from $200 oac WSID MEMBER One Call is all it takes! Toll Free ShepQuote.com Erin Shepard-nthony 3

6 W Dealer Penalized $1,750, By Kurt Strovink, JD There is a term in psychology known as the Dunning-Kruger effect. People tend to be blissfully unaware of their own incompetence, David Dunning and Justin Kruger wrote, Their lack of skill deprives them not only of the ability to produce correct responses, but also of the expertise necessary to surmise that they are not producing them. This isn t to say that people are stupid, it is merely a fancy way of stating the common sense rule You can t know what you don t know. The auto industry is different than many others in that the leaders in the auto industry often started on the ground floor as sales people. Those sales folks who do well, do so by sheer force of personality and a silver tongue. If they continue to do well, they make good money, get promoted, and perhaps ultimately end up owning their own dealership. What many of these fine sales folks don t realize is that the skills that helped them to succeed in sales do not directly translate to running a dealership. Being a strong salesman with no intent to do harm, will not, in fact, get you out of every bind. The Zein uto Group recently learned this lesson the hard way when they awoke one morning to discover that their bank accounts were frozen and their stores were in the process of being 4 raided by the federal government. When all was said and done, they were forced to pay a $1.75 million dollar penalty and were given a 2-year probation with the US Probation Office. It is important to remember that these large numbers do not even include the substantial cost of mounting their legal defense. I had the opportunity to sit down recently with Mohamad El Zein, one of the owners of Zein uto Group, to discuss what transpired at their store and help them spread the word so other dealers may benefit from their experience. Mohamad was very candid and had a lot of wonderful insight into the issues surrounding legal compliance for auto dealers. What follows is a synopsis of our conversation: Q: Your auto group was one of the largest independent dealers in W state. How many cars were you selling? : We were selling around 3,000 cars per year. Really, we grew too fast and that is where we failed. Even though we knew certain things to look out for, we failed to make certain that the proper procedures were in place so that every employee knew exactly what to do. Q: What was your dealership ultimately determined to have done wrong? : The dealership pleaded guilty to a single charge of Failure to File Required Monetary Transaction Report in reference to the IRS 8300 filing requirements. No one was individually charged, only the dealership as an entity. We ended up settling the case and place no blame on our employees. The judgment was solely against the corporation. Spring 2014 Q: How did your dealership s lack of procedure come to the attention of the authorities? : Several undercover agents came to our store at different times over the course of a few months. Once they arrived, they spoke to our sales department and explained that they wanted to buy a car but wanted to do so in a way that it would not be reported to the government. The government alleged that our sales people told the undercover agents that they would help facilitate the transaction. In one instance, the government alleged that the undercover agent said I m a drug dealer and asked how to get around the 8300 filing requirements. Q: Did you have any idea that your employees were engaged in this sort of activity? : None whatsoever. Q: Before all of this transpired, did you know anything about the 8300 rule? : We were generally aware of the 8300 requirements at the executive and managerial level. However, in some ways we were a victim of our own success. We went from selling 20 cars a month to over 300 in a short span of time and didn t implement processes to ensure that each of our employees knew the same things we did. What I find really interesting is that in two of the three instances of alleged misconduct, the 8300 forms were actually completed and placed in the deal jacket. So the employees in those instances knew what to do, did the right thing, but the forms were never properly filed with the appropriate agency. That is the process problem.

7 Q: s the head of education for WSID, I find it very difficult to get dealers to attend our compliance education events even when they are free of charge. Many dealers are apathetic and would not do any sort of continuing education whatsoever if it were not required by the state. It seems to me that most dealers feel nothing will ever happen to them and hope to just fly under the radar. What would you say to those dealers? : First off, that is so true and something we were guilty of ourselves. The issue is that dealers look at legal compliance as an afterthought. When we started our business, we sat down as owners and determined that sales are important. If you can t sell cars, you can t exist. Buying cars is important too if you don t buy cars, you can t sell them. The third part, legal compliance, was overlooked in favor of the profit centers. However, what we ve come to realize is that without compliance, you cannot hope to keep the profits you make. Imagine how many cars we will need to sell to make up the $1.75 million dollars we just lost. We ve worked so hard over the years and to lose that amount of money is devastating. Compliance is equally as important as buying and selling cars to the success of the business. You can sell 500 cars per month or make $5 million dollars per month but if you aren t taking steps to protect that, everything will disappear. The wake up call we got was significant. I think many dealers believe that so long as they aren t doing anything bad on purpose, they are fine. But it truly doesn t matter if you did something on purpose or not. I don t care if you didn t know about it, it is your job to know about it and make certain that it gets done. You need to treat compliance as you treat your sales department. You want your sales department to sell and you hold them accountable. The same should be done with compliance. Just as we have a budget for balloons, events, and forms we now have a budget for compliance. The biggest mistake a dealer can make is to think Hey, I only sell cars. I don t make money putting procedures in place. We learned the hard way that this mentality is wrong. We have since introduced a new compliance program with more strict procedures related to IRS Form 8300 reporting (more checks and balances). You and your dealership are ultimately responsible for what your employees do. I don t care how good your employees are or how high the numbers are, if they are doing something wrong you should expect the same wake up call we had! Q: Is there anything else you would like the dealers in Washington state to know? : s dealers we need to band together. We need to consider ourselves more as a brotherhood than merely competitors. If you look at other industries, they band together in support. We need a strong dealer association with dealers who care about doing things the right way. We need more education and a renewed emphasis on compliance. Q: I couldn t agree more. Dealers are beset on all sides by customers, attorneys general, the department of licensing, and federal agencies all looking for them to make a mistake. Hopefully, with the continued support of dealers like yourself, all dealers will come to realize compliance is crucial to their success. Thank you for taking the time to tell your story. Spring 2014 Federal Compliance Bootcamp: Learn to avoid the most common pitfalls of dealership compliance from our Executive Director! Dealerships are among the most heavily regulated businesses in the country. This 2 hour seminar will show you what to watch out for and teach you the procedures necessary to remain compliant. vailable to View: - In-Person - See Dates Below - Live Webinar - See Dates Below - Pre-Recording - nytime Dates vailable: - March 4 - Part 1, uburn - March 19 - Part 2, uburn - March 26 - Part 1, Spokane - pril 2 - Part 1, uburn - pril 23 - Part 1, Spokane - pril 28 - Part 2, uburn - May 6 - Part 1, uburn - May 22 - Part 2, uburn - May 28 - Part 1, Spokane Register Online! 5

8 By Kurt Strovink, JD Copyright Violations Disgruntled Employees Spring 2014 No matter the size of the business, everyone is looking for ways to cut costs. On occasion, the benefits of cutting corners will outweigh the risk. However, I respectfully submit that the unlicensed use of software and/or business forms is one cost cutting measure that should fall squarely in the more trouble than it is worth category. The fines are steep, the damages are easily proven, and most claims begin with a tip from a disgruntled employee. In fact, many copyright holders (the folks who create the software, documents, music, etc.) have instituted bounty-like reward programs in an effort incentivize employees to turn their employers in for copyright violations. How many of your employees would turn you in for a $1,000, reward? MEET THE BUSINESS SOFTWRE LLINCE The Business Software lliance (the BS ) is a nonprofit, self-funded alliance that advocates for enforcement of anti-piracy laws. The BS represents large software companies such as Microsoft, pple, and dobe. Recently, the BS has pursued claims against multiple dealers with settlements nearing $1,000, (One Million Dollars) and settled a claim with the lexander utomotive Group last March to the tune of $325, Per the chart below, the folks at the BS are presently offering rewards of up to $1,000, (One Million Dollars) for information leading to a settlement with a business found to be installing unlicensed software on computers that it owns or leases for its employees to use in their work. 6 Reward Payment Guidelines Settlement paid by Company Potential Reward payment $15,000 $100,000 Up to $5,000 $100,001 $200,000 Up to $10,000 $200,001 $400,000 Up to $20,000 $400,001 $600,000 Up to $30,000 $600,001 $800,000 Up to $40,000 $800,001 $1,000,000 Up to $50,000 $1,000,001 $2,000,000 Up to $100,000 $2,000,001 $3,000,000 Up to $150,000 $3,000,001 $5,000,000 Up to $250,000 $5,000,001 $10,000,000 Up to $500,000 $10,000,001 $15,000,000 Up to $750,000 Over $15,000,000 Up to $1,000,000 The most troubling aspect of this situation is that most dealers have very little technical expertise. I m certain that most dealers have no idea what the licensing requirements are for the software they use in their day-to-day operations. ccordingly, now would be an ideal time to review your software use policies and ensure that you aren t taking any unnecessary risks. If the BS comes knocking, they are going to request proof of purchase (i.e. receipts) for each copy of installed software. Invoices alone are not sufficient. One huge red flag is the the use of Microsoft Office version 2003 and earlier because all such editions are physically capable of being installed as many times as you want, on as many different computers as you want. BUSINESS FORMS Forms are an integral part of dealership operations. WSID spends thousands of dollars each year to assure that our forms pass muster with all federal, state, and local laws. When you use one of our forms, you can be assured that it does what it purports to do and won t leave you hanging by a thread should you ever end up in court. Unfortunately, a large number of inadequate forms have crossed my desk recently and the dealers who provided them were none to happy to discover that the forms they were using (to save costs) didn t protect them. In fact, one dealer s purchase order was so defective that it failed to provide him with a security interest in the vehicle he was financing for his customer. He discovered this shortly after his customer sold the car to someone else. Long story short, if you want to save a few pennies and create your own forms, make certain you run them by a dealer attorney who knows what to look for. Then pay that same attorney every year to review the forms to make certain that your forms remain in compliance with all federal, state, and local laws. If that sounds like too much trouble, buy your forms from WSID. -

9 Spring 2014 side from the inherent risks of using defective forms, some dealers have determined it is worthwhile to copy the forms they use which gives rise to copyright issues. Odds are the form is copyrighted. If it is, it will likely have a small c in a circle and perhaps some verbiage near the bottom with the word copywrite. This means that someone owns the content of that form and you can t use it without permission. The form and the way that it is arranged are someone s intellectual property. Using it without permission can expose you to a lawsuit and penalties of up to $75, per violation. 7

10 By Kurt Strovink, JD Many dealers have been cited by the DOL for improper practices related to the Emergency Medical Services Fee. Thankfully, the DOL has now set forth their view on the fee and how it should be handled. Section 5 of SSB5127, Providing for collection of the Emergency Medical Services Fee (sometimes referred to as the Trauma Care Fee ), became effective January 1, The question arises as to how a dealer is to disclose the fee. We are providing the following example to advise dealers on how they may disclose the fee in keeping with the itemization requirement of RCW : Because the dealer collects this licensing fee on behalf of the state and Trauma Care Fee Explained remits it to the state they are allowed to collect an administrative fee of $2.50 if disclosed properly. Per the Vehicle and Vessels Unit at the Department of Licensing, most licensing offices subtract the $2.50 administrative fee out of the License Fee that they quote/charge the dealership. So, the question becomes how to disclose the fee. We recommend the following example provided below: Example: Cash Price of Vehicle = $10,000 Total tax = $500 License Fee = $124 (mount quoted from your licensing office excluding in most cases the $2.50 to be kept by the dealer. The dealer remits this entire amount to the state.) Spring 2014 dministrative Fee = $2.50 (This amount is disclosed separately and is kept by the dealer) NOTE: Utilizing the name of dministrative Fee is consistent with RCW (1) listed below: The emergency medical services fee imposed under RCW must be distributed as follows: 1. If collected by a vehicle dealer, the vehicle dealer must keep two dollars and fifty cents as an administrative fee and the remainder must be deposited in the emergency medical services and trauma care system trust account created in RCW ; and 2. If not collected by a vehicle dealer, the fee must be deposited in the emergency medical services and trauma care system trust account created in RCW

11 Spring 2014 The Used Car Rule and Private Lawsuits By Kurt Strovink, JD Those who have taken my Federal Compliance Bootcamp heard me speak at length on the perils of failing to comply with the Used Car Rule (a.k.a Buyer s Guide or S-IS sticker). In brief, before any used vehicle is offered for sale, a Buyer s Guide must be prominently and conspicuously displayed within it. If you violate this rule, you are subject to a $16, penalty per violation. The court determined that a private right of action exists for violations of the Used Car Rule because it was created pursuant to the Magnuson Moss Warranty ct, which itself creates a private right of action. Thus, it is no longer sufficient to merely worry that the government can penalize you for Buyer s Guide violations; your customer can now sue you as well. If there was a saving grace to the rule, it had to be that there was no way for an individual car purchaser to sue you for failing to provide a Buyer s Guide the government had to do it. This was my interpretation because to date there had never been an instance where a private citizen was able to successfully use the Used Car Rule against a dealer in a private suit. Sadly, this has now changed and you must be ever more vigilant. Mr. & Mrs. Nasser purchased a vehicle which did not have a Buyer s Guide on it and they were not provided with one after they purchased the car. Within an hour of purchase, the vehicle s check engine light came on and within the following months the Nassers experienced a multitude of other problems with the vehicle. The vehicle was returned to the dealer on two different occasions but it was not repaired. see Nasser v. Wiz Leasing, Inc., 2013 Conn. Super. LEXIS 1801 (Conn. Super. ugust 12, 2013) The Nassers ultimately returned the car to Wiz but Wiz refused to refund the purchase price. In the ensuing legal battle, the Nassers sued Wiz for, among other things, failing to display and provide them with a copy of the Buyer s Guide. ccordingly, the Nassers argued that they had not been informed the vehicle was sold S IS. 9

12 November 2013 Wenatchee fined $7,000. Spokane Finding: Sold 2 vehicles that didn t meet state emission requirements, but unwound the transactions when they found out about the status of the vehicles. ction: Fined $500, which is stayed (not imposed) for 1 year as long as there are no similar violations. rlington fined $6,000. Lakewood ction: Ordered to cease and desist, and fined $5,000. The fine is stayed (not imposed) for 1 year as long as there are no similar violations. Federal Way fined $7,000. Tacoma Finding: Failed to disclose that a vehicle had been destroyed and rebuilt. ction: Fined $1,000 and license suspended for 3 days. The suspension is stayed (not imposed) for 1 year, as long as there are no similar violations. Seattle fined $5,000. Tacoma Finding: Failed to disclose that a vehicle had been destroyed and rebuilt. ction: Fined $1,750. Bremerton Finding: Late title transfer. ction: Fined $ Sultan fined $2,000. October 2013 Everett fined $3,500. Spokane Finding: Sold a vehicle that didn t meet vehicle emissions standards. ction: Fined $250. Seattle ction: Ordered to cease and desist, and fined $6,000. The fine is stayed (not imposed) as long as there are no similar violations for 1 year. Lakewood fined $6,000. Seattle ction: Ordered to cease and desist, and fined $9,000. The fine is stayed (not imposed) as long as there are no similar violations for 1 year. Quincy Finding: Sold a vehicle without clearly disclosing in writing on the purchase order agreement that the vehicle is an insurance salvage rebuilt. ction: Fined $1,000, which is stayed (not imposed) as long as there are no similar violations for 1 year. Everett fined $1,500. Battle Ground Finding: dvertisement violations. ction: Fined $500. Spring 2014 dministrative ction gainst Dealers Puyallup Finding: On 3 separate occasions, sold and failed to disclose on the face of the purchase order that the vehicles had been totaled out by an insurance company and rebuilt. Failed to request a hearing and/or return a signed greed Order. ction: Fined $3,000. Tacoma Finding: Several cases of: Late title transfers Overcharged fees Bushing Misrepresentation of down payments Finding: Fined $25,000. Vancouver ction: Ordered to cease and desist, and fined $6,000. The fine is stayed (not imposed) as long as there are no similar violations for 1 year. Vancouver fined $5,000. Tacoma ction: Ordered to cease and desist, and fined $6,000. The fine is stayed (not imposed) as long as there are no similar violations for 1 year. Beverly ction: Ordered to cease and desist, and fined $5,000. The fine is stayed (not imposed) as long as there are no similar violations for 1 year. uburn Finding: Late title transfers. ction: Fined $8,500. Tacoma fined $5,000.

13 PLN HED: complete your 5 continuing education credits BEFORE your next renewal. Continuing Education Requirements: 1.) Complete 3 Read & Respond Quizzes Quiz 1 Quiz 2 Quiz 3 2.) ttend One Seminar Class Complete at least 2.5 hours

14 Spring 2014 Washington State Independent uto Dealers ssociation Read & Response Spring The Business Software lliance is enticing employees to turn in businesses using unlicensed software. Turning a business in for using such software may earn the whistleblower a reward of up to $1,000, True B False 2. Using forms that are not regularly reviewed by an attorney familiar with the laws in Washington exposes you to significant liability. 6. The CFPB recently settled a claim against GM s former finance arm for $98 million dollars. The CFPB determined that rate mark-up resulted in a pattern or practice of discrimination against a prohibited class. B True False 7. While the CFPB has yet to clarify what dealers can do to shield themselves from a discrimination claim, a dealership should consider: True B False 3. Copying a form and/or using it without permission can expose you to penalties of up to $25, per violation. True B C Capping dealer participation in the loan rate to 2.5% for contracts under 60 months. Capping dealer participation in the loan rate to 2.0% for contracts over 60 months. Documenting the good faith, competitive reasons for lowering the dealer rate participation. B False 4. If you are investigated by the BS, invoices for each copy of installed software is sufficient proof that you paid for the license to use it. True B False 5. The Consumer Finance Protection Bureau is actively investigating the propriety of dealers retaining a mark-up on loans made to consumers. D E F Instituting new policies so that dealers do not participate in the loan rate for loans made to minority groups. Instituting new policies so that dealers do not Participate in the loan rate for loans made to persons from different nations. ll of the above. G ll of the above except D. True H ll of the above except D & E B False 12

15 8. Referring customers to service providers that are not properly licensed/certified to perform the work could make render your dealership liable for the damage done by the service provider. B True False 9. Compliance procedures are not as important as buying and selling cars to the success of a dealership. You must focus on the profit centers for your business. So long as you don t intend to do wrong, everything will be fine. B 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: 13

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