Loss of Use: Is the At-Fault Driver’s Insurer Required to Provide a “Comparable” Rental Vehicle?


IMG_3280So my car got rear-ended while legally parked next to the curb in front of my house by a car traveling around 35-40 miles per hour. Fortunately, the teen-aged driver of the other car (depicted in the photograph) was insured and didn’t suffer any injuries. Unfortunately, the teenager’s insurance company (I’ll refer to it as ABC Insurance Company) didn’t understand the law of loss of use damages or its obligations under the property damage liability coverage of the auto policy it issued to the teenager.  

My car got hammered. I happened to be on my front steps drinking a cup of coffee at the time and saw the accident. The force of the impact caused my car to be propelled over 150 feet down the street and into and over the curb on the other side. It was in the shop for three weeks. 

At the outset, ABC told me they’d only pay for a compact-sized rental car while mine was in the shop for repairs. My car is mid-size. I told them I’d try it, but that ABC was obligated to pay all damages their insured caused and I was entitled to a comparable mid-size car. I tried the compact for three days. It was too small and provided absolutely no lumbar support so I “upgraded” to a Kia Optima – a mid-size car. The upgrade cost around $10 per day. Upon learning of this, ABC refused to pay the $10 daily difference between the compact and the Kia. ABC told me they had an internal rule of only reimbursing third-party claimants for the cost of a compact vehicle, rather than a comparably-sized vehicle, and they were only required to provide “transportation.” I politely disagreed, advising that I didn’t care about their internal rule; that I was entitled to reimbursement based on the cost to rent a comparably sized vehicle. 

The amount at issue wasn’t that much (around $190 at the time my vehicle was fixed), but it was the principle of the thing. 

So, I proceeded to do some legal research. I knew I wouldn’t find anything exactly on point in Minnesota, but assumed I’d find law to support my view elsewhere. 

The results of my research:

Virtually all states recognize the right of an automobile owner to recover damages for the loss of use of the damaged vehicle while it is being repaired. See, Kopischke v. Chicago, St. P., M. & O. Ry. Co., 230 Minn. 23, 30–31, 40 N.W.2d 834, 839 (1950); Hanson v. Hall, 202 Minn. 381, 387–388, 279 N.W. 227, 230–231 (1938); Restatement (Second) of Torts § 928(b) (1979); 4A Minn. Prac., Jury Instr. Guides–Civil CIVJIG 92.10. 

The purpose of awarding loss-of-use damages is to provide compensation for monetary loss and inconvenience suffered during the time required to repair the damaged vehicle. 

I found no cases supporting ABC’s internal policy that it was only obligated to provide “transportation.” 

I found several cases stating that the reasonable value of the loss of use of an automobile is measured by the rental cost of a comparable vehicle. See, e.g., AT & T Corp. v. Lanzo Const. Co., Florida, 74 F. Supp. 2d 1223, 1225 (S.D. Fla. 1999) (“loss of use damages are measured by the amount necessary to rent a similar article or other suitable article within which to perform the services usually performed by the damaged article during the period of repair”); Lewis v. Lawless Homes, Inc., 984 S.W.2d 583, 586 (Mo. Ct. App. 1999) (“The value of its use is the cost of renting a similar piece of equipment”); Papenheim v. Lovell, 530 N.W.2d 668, 673 (Iowa 1995) (awarding loss of use damages based on rental rate for full-size vehicles similar to plaintiff’s damaged full-size vehicle); Chlopek v. Schmall, 224 Neb. 78, 89, 396 N.W.2d 103, 110 (1986) (“The reasonable value of the loss of use of personal property is generally the fair rental value of property of a like or similar nature or the amount actually paid for rental, whichever is less”); Lamb v. R.L. Mathis Certified Dairy Co., 183 Ga. App. 455, 457, 359 S.E.2d 214, 216 (1987) (“plaintiff would be entitled to reasonable rental value of a comparable car for a reasonable length of time to have the body repairs completed”); Lenz Const. Co. v. Cameron, 207 Mont. 506, 509-10, 674 P.2d 1101, 1103 (1984) (“We do not disagree with using, as a general measure of loss-of-use damages, the reasonable rental value of a comparable machine for the period of time necessary for replacement”); Gillespie v. Draughn, 54 N.C. App. 413, 417, 283 S.E.2d 548, 552 (1981) (“The measure of damages to be recovered is the cost of renting a similar vehicle during a reasonable time for repairs”); Apostle v. Prince, 158 Ga.App. 56(2), 279 S.E.2d 304 (1981) (“The plaintiff expressed his opinion as to the reasonable rental value of a comparable car. There was sufficient evidence presented to allow the jury to determine damages for loss of use”); Roberts v. Pilot Freight Carriers, Inc., 273 N.C. 600, 607, 160 S.E.2d 712, 718 (1968) (“Ordinarily the measure of damages for loss of use . . . is the cost of renting a similar vehicle during a reasonable period for repairs”); Nat’l Dairy Products Corp. v. Jumper, 241 Miss. 339, 344, 130 So. 2d 922, 922-24 (1961) (“In short, loss of use of a repairable vehicle is measured by the reasonable rental value of a similar unit . . . This measure of damages for loss of use has the virtue of certainty and fairness, in that there can ordinarily be determined specifically the value of the loss of use, by ascertaining the rental value of a similar vehicle”); Naughton Mulgrew Motor Car Co. v. Westchester Fish Co., 105 Misc. 595, 597, 173 N.Y.S. 437, 438 (App. Term 1918) (“The practice has obtained in these damaged vehicle cases of allowing the cost of the actual hire of another vehicle similar to that damaged”). 

Stated simply, the liability insurer of the at-fault driver is obligated to pay for the rental cost of a vehicle similar or equal to the vehicle that was damaged while the damaged vehicle is undergoing repairs. If a compact car was damaged, the owner is entitled to recover the cost to rent a similar compact-size car. If a mid-size car was damaged, the owner s entitled to recover the cost of a similar mid-size car. If a truck was damaged, the owner is entitled to recover the cost to rent a truck. It’s pretty simple — at least in my view. 

I gave ABC one more chance to pay my bill. I figured if they told me “no” three times, they’d strike out and I’d have to sue. 

 This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

Posted in Coverage, PAP, Rentals | 1 Comment

Auto Dealer Risk Management: Negotiating Dealer-Lender Agreement Terms


images (15)Car sales are booming and lenders are clamoring for indirect financing business.  Now is a great time for dealers to dust off and review their Dealer Agreement (a/k/a lender master financing agreements) with lenders, particularly the warranty, indemnification and repurchase provisions. Dealerships can, and should, review the terms of their Dealer Agreements on an annual basis and negotiate the provisions of those agreements to reduce the potential of a large, uninsured repurchase exposure. 

Dealer Agreements (“DA”) are drafted by attorneys for the lender and, as such, are quite favorable to the lender. The typical DA requires the dealership to warrant that it “will comply with all applicable federal, state and local laws, rules and regulations including without limitation all consumer protection and consumer credit laws, the Federal Truth in Lending Act and Regulation Z, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act and the Federal Equal Credit Opportunity Act and Regulation B.” 

The DA will then mandate that the dealer repurchase any retail installment sales contract (RISC) the lender violates federal or state law regardless of whether (a) the customer defaulted on the RISC; (b) the customer claimed the dealership violated any law; (c) the violation (if proven) caused the customer or lender any damage or harm; (d) the dealership had actual knowledge or even reason to know it was violating a law; or (e) the dealership was even the party responsible for the violation. 

For a partial listing of federal and state laws that regulate auto dealerships, see my article: Auto Dealer Arranged Financing:  51 Laws Dealers Must Know (here) 

The lender repurchase exposure is quite problematic from a dealership’s standpoint: 

First, typical garage liability (a/k/a auto dealer coverage form) policies will not protect the dealership against lender repurchase claims. Many garage policies are limited to suits brought by customers, not suits brought by lenders. A typical policy requires the insurer to “pay on your behalf all sums you legally must pay as damages because of a claim or suit brought against you by a customer during the policy period.” In addition, most liability policies contain a contractual liability exclusion barring coverage for “liability for which the [dealership] has assumed in a contract or agreement.” This means the dealership’s policy will not cover the cost of defending the dealership in litigation commenced by the lender much less indemnify the dealership for any amounts it may be required to pay the lender to repurchase the RISC. The uninsured exposure can be significant, particularly if the violation stemmed from an ongoing business practice and affected hundreds, if not thousands, of RISCs. 

Another problem is that the typical DA obligates the dealership to pay the full repurchase price regardless of whether the vehicle has been damaged or has been forfeited due to seizure, impoundment or abandonment. Further, the typical DA provides that the lender has no obligation to repossess or otherwise secure the vehicle for the dealership as a condition of requiring the dealership to repurchase the RISC. In short, the dealership may be contractually obligated to pay the full repurchase price on a vehicle (or vehicles) that is entirely worthless or cannot even be located. 

The dealership in Mid-Century Ins. Co. v. Vinci Inv. Co., Inc., 2010 WL 673267 (Cal. Ct. App. Feb. 25, 2010), was lucky, at least in part. In that case, the credit union’s lawsuit against the dealership involved the RISCs of over 200 customers. The credit union claimed the dealership was required to repurchase those contracts because it had failed to disclose deferred downpayments which it claimed violated the California Automobile Sales Financing Act (“ASFA”) and Regulation Z, 12 C.F.R. section 226.18. The credit union demanded in excess of $1.5 million in settlement. The dealership’s insurer, Mid-Century denied coverage for the repurchase lawsuit. However, the policy contained a rather bizarre insuring clause obligating the insurer to defend against and “pay all sums . . . involving any negligent act, error or omission committed by the [dealership] in failing to comply with [TILA] or any State law on Truth in Lending.” Noting that the term “involving” is a very broad term, the California Court of Appeals determined that Mid-Century was at least obligated to pay for the dealership’s defense in the lawsuit. The case was remanded to the trial court for a determination of whether Mid-Century was obligated to pay any part of the $1.5 million dollar demand.  It is important to note that the term “involving” does not appear in any current dealership garage liability policy forms. 

Dealerships can, and should, review the terms of their DAs on an annual basis and negotiate the provisions of those agreements to reduce the potential of a large, uninsured repurchase exposure. This annual review should be incorporated into the dealership’s Compliance Management System. While lenders hold the cards and can insist on their boilerplate contract terms when the economy is down and credit is tight, dealerships can demand modification of terms today, particularly if they do a large amount of business with the lender and have the ability to direct that business elsewhere. 

This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

 

Posted in ADCF Policy, Auto Dealer, Indirect Financing, Regulatory Compliance | Tagged , , , , , | Leave a comment

CFPB to Allow Consumers to Voice Complaints Publicly


untitled (19)Auto Dealer Monthly recently reported on the Consumer Financial Protection Bureau’s announcement that it is finalizing a policy to allow consumers to voice publicly their complaints about consumer financial products and services:

Now, when consumers submit a complaint to the CFPB, they have the option to share their account of what happened in the CFPB’s public-facing Consumer Complaint Database. The CFPB is also publishing a request for information seeking public input on ways to highlight positive consumer experiences, such as by receiving consumer compliments.

“Consumer narratives shed light on the full consumer perspective behind a complaint,” said CFPB Director Richard Cordray. “Narratives humanize the problems consumers face in the marketplace. Today’s policy will serve to empower consumers by helping them make informed decisions and helping track trends in the consumer financial market.”

The announcement didn’t sit well with American Financial Services Association, which issued a statement critical of the CFPB’s new policy to F&I and Showroom. “Because consumers are likely to assume a level of accuracy and validity in the complaints posted on a government website, the CFPB’s publicizing unsubstantiated consumer narratives that could mislead consumers,” stated Bill Himpler, the association’s executive vice president. “In additional, publishing unverified and unfiltered claims could pose significant brand and reputational risk to financial services companies.”

You can read the full article here:

CFPB to Allow Consumers to Voice Complaints Publicly.

This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

Posted in CFPB | Leave a comment

Auto Dealers & Regulatory Compliance: If the FTC Comes Knocking


images (8) Dealerships have become subject to increased regulation and enforcement, particularly in the areas of consumer advertising, consumer finance and consumer privacy. I recently posted an article to this blog entitled: Auto Dealer Arranged Financing: 51 Laws a Dealer Must Know. You can read the full article here.

Most dealers recognize that the legal landscape has changed. While consumer litigation and associated class actions persist (and the incidence of class action litigation has increased over the past few years), federal regulatory authorities are the new player in town and they are joining with the Department of Justice and local authorities to enforce compliance with federal and state laws. Indeed, on March 26th, the Federal Trade Commission (FTC) and 32 law enforcement partners announced the ongoing results of Operation Ruse Control, a nationwide and cross-border effort which has thus far resulted in over 250 enforcement actions (187 in the U.S.) as well as six new FTC cases. The FTC cases have included allegations of deceptive advertising, auto financing application fraud, odometer fraud and deceptive marketing of car title loans. In addition, and for the first time since receiving expanded authority over auto dealers under the Dodd-Frank Act, the FTC has taken two enforcement actions involving F&I product add-on charges. Examples of F&I product add-ons include service contracts and extended warranties, guaranteed automobile protection (commonly called GAP or GAP insurance), credit life and disability insurance, road service, theft protection, undercoating and payment programs. The six new FTC cases include more than $2.6 million in monetary judgments. The sweep follows on the heels of the FTC’s Operation Steer Clear campaign against 10 dealerships in 2014.

“The clear message is that across this country, and indeed internationally, law enforcement agencies are on the lookout for deceptive and illegal practices by auto dealers, and will take whatever action is necessary to protect consumers,” said Jessica Rich, director of the FTC’s Bureau of Consumer Protection.

The majority of dealers take their compliance obligations very seriously as non-compliance can result in consumer litigation, regulatory enforcement actions and lender repurchase claims as well as the payment of actual damages, statutory damages, monetary penalties and fines, injunctive relief and potentially punitive damages and criminal fines. Negative publicity is a virtual certainty as well. Those striving to comply with the myriad laws regulating the dealership industry are (1) appointing a Consumer Regulatory Compliance Officer; (2) integrating an Advertising, Sales and F&I Manual (with federal and state specific policies and procedures) into their Compliance Management System (CMS); (3) providing regular training to their staff on those policies and procedures; (4) auditing compliance with those policies and procedures; and (5) monitoring legal and regulatory changes. A well planned, implemented, and maintained compliance program will prevent or reduce regulatory violations, provide dealership cost efficiencies and is just sound business. If the FTC comes knocking on your dealership door, you should not only be able to tell them what you are doing, but also show them what you are doing to comply with the laws. If your CMS does not specifically address the 51 laws and regulations cited in my article as well as the practices which have historically produced the greatest amount of consumer litigation and regulatory actions (call me and I’ll tell you what they are – I’ve defended dealerships in litigation alleging each one), your compliance program is not a true CMS – it is inadequate.

This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

Posted in Auto Dealer, Consumer Leasing Act, Errors & Omissions, Indirect Financing, Regulatory Compliance, TIL Disclosures, Truth in Lending Act | Tagged , , , | Leave a comment

Auto Dealer Arranged Financing: 51 Laws Dealers Must Know


Compliance PICIt’s no secret that auto dealerships have become subject to increased regulation over the past several years, primarily in the areas of consumer advertising, consumer finance and consumer privacy. Although the recession of 2007-2009 was primarily related to mortgage financing, regulatory agencies such as the Consumer Financial Protection Bureau (CFPB) (created by the Dodd-Frank Act in 2010), Department of Justice (DOJ), Federal Trade Commission (FTC) and state attorney’s general are focusing on auto dealership financing as well. While the CFPB does not have regulatory authority over auto dealerships, they are exercising indirect authority through their authority over lenders that buy retail installment contracts from dealers. In addition, the CFPB has collected a great deal of information on the dealership industry that they, in turn, share with other government agencies that do have regulatory authority over dealers.

At present, the CFPB is attacking the dealer reserve, where dealerships typically add one percentage point or two to a lender’s wholesale interest rate as compensation for facilitating the indirect financing. The CFPB contends the dealer reserve system has led to unintended lending discrimination and wants to impose a flat fee system. Next up, the CFPB will probably attempt to regulate the pricing of ancillary F&I products sold by dealerships. The CFPB has been collecting data and will likely claim that charges for certain products by some dealerships exceed their value and will attempt, through enforcement actions, to impose retail price caps.

Meanwhile, dealerships must comply with all existing federal, state and local laws and regulations that pertain to the sale and financing of motor vehicles and the non-public, personally identifiable information provided to the dealership by its customers. This is an absurdly large and exceptionally complex task, even for large auto dealerships who employ in-house legal counsel. Below is a list of my top 51 laws and regulations that auto dealerships must thoroughly understand (and should incorporate into their Compliance Management System (CMS)) to avoid liability, whether in the form of consumer litigation or regulatory enforcement actions. Keep in mind that this list is not all-encompassing (it’s only my top 51) and each law or regulation cited has many sub-sections (i.e., even more laws and regulations):

  1. Federal Trade Commission Advertising Rules
  2. State Advertising Laws & Regulations
  3. CAN SPAM Act & FTC E-Mail Rules
  4. CAN SPAM Act & FCC Texting (Internet Domain)Rules
  5. Telephone Consumer Protection Act & FCC Regulations
  6. Federal Trade Commission Texting (Phone) Rules
  7. Federal Trade Commission Autodialer Rule
  8. Federal Trade Commission Do Not Call Rule
  9. Telemarketing and Consumer Fraud and Abuse Prevention Act
  10. Federal Trade Commission Telemarketing Sales Rule
  11. Deceptive Mail Prevention and Enforcement Act
  12. Junk Fax Prevention Act & FCC Regulations
  13. Gramm-Leach-Bliley Act (GLBA) & Regulations
  14. Federal Trade Commission Privacy (Notice) Rules
  15. Federal Trade Commission Privacy (Information Sharing) Rules
  16. Federal Trade Commission Information Safeguards Rule
  17. Federal Trade Commission Pretexting Provisions
  18. FACTA Red Flags Rule (Identity Theft Prevention Program)
  19. FACTA Information Disposal Rule
  20. Federal Trade Commission Section 5 UDAP Prohibitions
  21. Computer Fraud and Abuse Act (CFAA)
  22. Electronic Communications Privacy Act (ECPA
  23. Driver’s Privacy Protection Act (DPPA)
  24. Truth & Lending Act & Regulation Z
  25. Consumer Leasing Act & Regulation M
  26. State Retail Installment Sales Acts-Disclosure
  27. State Retail Installment Sales Acts-Usury
  28. Equal Credit Opportunity Act-Discrimination
  29. Equal Credit Opportunity Act-Adverse Action
  30. Fair Credit Reporting Act-General Provisions
  31. Fair Credit Reporting Act-Adverse Action
  32. Federal Trade Commission Credit Practices Rules
  33. Federal Trade Commission Risk-Based Pricing Rule
  34. State Insurance Statutes & Regulations
  35. State Service Contract Statutes & Regulations
  36. Electronic Funds Transfer Act & Regulation E
  37. IRS Form 8300 Cash Reporting Rule
  38. USA PATRIOT Act and OFAC Requirements
  39. Servicemembers Civil Relief Act
  40. Fair Debt Collection Practices Act
  41. Uniform Commercial Code (Repossession)
  42. State Consumer Fraud Prevention Acts
  43. State Unfair & Deceptive Trade Practices Acts
  44. Federal Network Security and Data Privacy Laws
  45. State Network Security and Data Privacy Laws
  46. Federal and State Odometer Acts
  47. State Title Branding Laws
  48. Federal Trade Commission Used-Car Rule
  49. Magnuson-Moss Warranty Act
  50. State New Vehicle Lemon Laws
  51. State Dealership Licensing Laws & Regulations

This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

Posted in Auto Dealer, Dealer Reserve, Errors & Omissions, Indirect Financing, Regulatory Compliance, TIL Disclosures, Truth in Lending Act | Tagged , , , | 3 Comments

Hey Dealer, Can I Get a Loaner?


MADA Loaner Vehicle

I recently wrote an article for the Minnesota Automobile Dealer Association’s MN Dealer Outlook Magazine (Winter 2015).  If your Minnesota dealership provides dealer-owned loaner vehicles to customers while the customer’s vehicle is being repaired, you’ll want to read on.

Minnesota is one of just twelve states where vehicle owners can be held liable for damages and personal injuries involving their vehicle.  This type of liability is called “vicarious liability” and is created by a Minnesota statute which provides that a vehicle owner is liable for all injuries and damages caused by a permissive driver.

So, when you flip a customer the keys to a loaner vehicle and he collides with another car causing injuries and damages, you can be on the hook too – not because you’ve done anything wrong but because you happen to own the vehicle.

While the customer will hopefully have a personal auto policy (you’ll want to verify insurance before issuing a loaner) and that policy will be primary, it will often be insufficient to cover all injuries and damages, leaving the dealer liable to the injured parties for the balance.

There’s a Federal law called the “Graves Amendment” which some commentators have suggested will protect the dealer against vicarious liability in the loaner context.  That’s probably not true.  While the Graves Amendment protects those “engaged in the trade or business of renting or leasing vehicles,” it likely does not apply to dealers providing loaner vehicles.  The problem is “loan” versus “rent.”  At least two courts have refused to extend the protections of the Graves Amendment where no rental payments were made.

But all is not lost. A dealer can limit its vicarious liability for loaner vehicles.  Minnesota Statutes cap a dealer’s vicarious liability for loaner vehicles if the dealer maintains insurance covering itself against losses up to at least the amount of the caps.  For calendar year 2015 the caps are: $155,000 per person/$465,000 per accident for bodily injury and $75,000 for property damage.  Make sure your garage liability insurance affords coverage for loaner vehicles in at least these amounts and that the terms of your written loaner agreement are entirely consistent with your policy and the statute.

Verifying a customer’s insurance is important for another reason.  Your loaner may be damaged, totaled or stolen while in the customer’s possession.  In this regard, Minnesota law is quite favorable.  It provides that the property damage coverage of the customer’s policy is automatically rewritten to afford at least $35,000 of coverage for damage to, or loss of, a loaner (or rental) vehicle. Depending on the terms of your loaner agreement, this coverage can be imposed regardless of whether the customer was negligent or otherwise at fault.  To take advantage of this law, you’ll want to make sure your loaner agreement clearly outlines the customer’s obligations, has the required consumer protection notices and otherwise fully complies with the statute.

Note that we’re talking about service loaner vehicles here.  In general, rental vehicles offer less exposure for the renting dealership.  However, loaner vehicles and demos offer more exposure for dealers.

This blog is for informational purposes only. By reading it, no attorney-client relationship is formed. The law is constantly changing and if you want legal advice, please consult an attorney. Gregory J. Johnson ©All rights reserved. 2015.

 

Posted in ADCF Policy, Auto Dealer, Coverage, Rentals | Tagged , , , , , | Leave a comment

Speaking at Automotive Dealer Subprime Sales Success Workshop on April 7-8th in Atlanta, Georgia.


99281cd1-8fa6-4b14-8cf7-c1daff274a7e-medium (2)I will be a speaker at the Automotive Dealer Subprime Sales Success workshop on April 7-8th in Atlanta, Georgia. I will be speaking on two related topics.  First, about F&I compliance and class action litigation issues (spot delivery, acquisition fees, deferred down payments, credit discrimination, adverse action, recontracting-backdating, among others).  Second, I will be addressing auto dealer liability insurance coverage (or non-coverage) for consumer protection, consumer credit and consumer privacy litigation under the Truth in Lending Act (TILA) and Regulation Z, Consumer Leasing Act (CLA) and Regulation M, Equal Credit Opportunity Act (ECOA) and Regulation B, Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Gramm-Leach-Bliley Act (“GLB”), Federal Trade Commission’s (FTC) Advertising, Privacy, Safeguards and Used-Vehicle Rules and similar state statutes and regulations as well as claims alleging consumer fraud and deceptive and unfair business practices.

The two-day workshop, being conducted by Becky Chernak of Chernak Consulting, will feature presentations by Dealertrack Technologies, Automotive Dealer Institute, Champion Strategies, Equifax, LoJack, Complí and Becky Chernak.

More information about the seminar can be found here:

www.autoremarketing.com/subprime/subprime-workshop-feature-chernek-dealertrack-equifax

Posted in ADCF Policy, Auto Dealer, Coverage, Indirect Financing, Regulatory Compliance, Truth in Lending Act, Truth in Lending Coverage | Tagged , , , , , , , , | Leave a comment