FTC Civil Investigative Demand

I just read a Federal Trade Commission (FTC) Civil Investigative Demand (CID) to a dealer surrounding the use of a bi-weekly payment plan. The purpose of this post is to alert you to a new interrogatory in the CID that I have not seen in previous ones. The FTC asks...

Disparate Impact Virtual Review

The Consumer Financial Protection Bureau (CFPB) provided guidance to indirect auto finance lenders earlier this year of the CFPB’s requirement for compliance with the Equal Credit Opportunity Act (ECOA). Certain members of the House of Representatives penned a letter...

How Solid is your Dealership’s Out of Area Delivery Policy?

I recently reviewed an identity theft case. Here’s the horror story showing how crafty the thieves are getting. The victim and thief were from out of state. The dealer verified the victim’s address before sending the document package with an overnight service. A few...

Chrysler Capital – No Negative Equity on Leases!

It has come to my attention and confirmed by email that it is Chrysler Capital’s corporate policy to not permit negative equity on leases. This is a credit underwriting decision and policy, not a disclosure policy. Chrysler Capital simply does not want any lease...

Disparate Impact and Auto Dealerships

Today many publications ran a story concerning the Consumer Financial Protection Bureau (CFPB). This agency has oversight responsibility for certain financial institutions, but auto dealers who sell and service vehicles are exempt from its oversight. This report from...

WardsAuto Webinar Series – Modern F&I: A Balancing Act

August 10, 2012:  gvo3 & Associates is excited to announce that Gil Van Over has been invited to participate as a panelist for the WardsAuto Webinar Series. The session topic is Modern F&I: A Balancing Act. The panelist will discuss how dealers succeed in...

Automotive News – F&I Week Online Conference

June 28, 2012:  Last week, Gil Van Over had the opportunity to be a panel speaker at the 2nd Annual Automotive News – F&I Week online conference. The session topic was Smart Phones & Mobile Tablets: The 4-1-1 You Need To Know To Connect With...

FTC Credit Score Disclosure Rule Stands

May 25, 2012:    NADA lost the first round in what promises to be a heavyweight fight with the FTC this week.  At issue is the FTC’s interpretation of a dealer’s responsibility in providing notices to consumers as required by the Risk Based Pricing Rule....