10-Steps for Navigating Advertising, Sales & Finance Compliance

 

Step 1

Establish a Compliance Team

• Department Managers:
  • Marketing
  • Sales
  • Finance
  • Accounting
• Meet Quarterly
• Track Progress

 

Step 2

Written Programs, Plans, and Policies

• Consumer Compliant Management Program
• OFAC Policy
• Red Flags/Identity Theft Prevention Program (ITPP)
• Fair Credit Program
• Voluntary Protection Program

 

Step 3

Ongoing Trainings and Certifications

• Adverse Action Rule
• Equal Credit Opportunity Act (ECOA)/Reg B
• Fair Credit Reporting Act (FCRA)
• Financial Privacy Rule
• IRS Form 8300
• OFAC
• Red Flags Rule
• Risk Based Pricing
• Unfair Deceptive and Abusive Acts and Practices (UDAAP)
• + more

Step 4

Deal Jacket Audits

Conduct deal jacket audits via secure upload (or in-person) for:

• Improper Disclosures
• Missing Forms
• Incomplete Documents
• F&I Manager Trends
  
  

Step 5

Website, Social Media, and Advertising Assessments

Spot assessments of website for:

• Reg Z Violations
• Reg M Violations
• State Law Violations
• Violations of Motor Vehicle Trade Regulation Rule (if passed)
  

 

Step 6

Lot Management Assessments

Spot assessments of lot management for:

• Monroney Sticker Violations
• FTC Buyers Guide Violations
• Key Fob Control
• Plate/Tag Management

 

Step 7

Track Issues to Resolution

Flagged issues from periodic assessments:

• Automatically generate and assign eTasks
• eTasks may be reassigned
• eTasks are tracked until resolution
• Resolutions are fully documented
  
  

Step 8

Consumer Complaint Management (FairShake)

Capture and resolve consumer complaints before regulator involvement:

• Complaint Form Accessed via:
  • Website Link
  • Email Link
  • QR Code (on signage at facility)
  • Assigned Agents
  • Escalation
  • Documented Communications
  • Dynamic Dash Boarding for Analyzing Complaints
    
    

Step 9

Quarterly Meetings

• Review Progress
  • Training
  • Assessments
  • Remediation
• Industry News
• Best Practices
• Complaint and Claims Review for Implementing Remedial Measures
  
  

Step 10

Annual Reporting

The following reports are prepared annually for executive leadership:

• Annual report of proactive efforts for insurance carrier
• Red Flags/ITPP annual review
• Consumer complaint trend analysis