June 2014 Issue FIADA Independent Dealer Magazine

Page 1

SINCE 1940

www.FIADA.com

JUNE 2014

A Publication of the Florida Independent Automobile Dealers Association

Information and Insight for Florida Used Car Dealers

We have the supplies your business needs:

10

Claim Your Sales Tax Refund

12

Dealer Open Lot Coverage

20

Have a Plan

Or leave the money on the table. The choice is yours when it comes to repos and bad debts.

Read your policy and know what it says before you make a claim.

Best practices of successful dealers.

FULTON, MO PERMIT NO. 38

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June 2014 — Independent Dealer — 1


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Dealer Independent

MAILING ADDRESS 1840 Fiddler Court Tallahassee, FL 32308 TELEPHONE (850) 385-2712 (800) 237-0448 FAX (850) 385-3251 WEBSITE www.FIADA.com EXECUTIVE COMMITTEE Dino Mercurio President Jim Winterick, Sr. Senior Vice President Christopher Leedom Chairman of the Board Phil Risley Secretary Paul Matton Treasurer Lisa Compagno Regional Vice President Frank Fuzy Regional Vice President George Hickey Regional Vice President Steve Marbais, CMD Regional Vice President Govinda Romero Regional Vice President FIADA STAFF Lisette Mariner Executive Director Terry Myers Educational Instructor Sarah Langley Administrative Director Nicole Lee Development Administrator Amelia Tillman Member Services Christy Taylor Editorial/Advertising

POSTMASTER:

Contents June 2014

For members of the Florida Independent Automobile Dealers Association

C O L U M N S & F E AT U R E S 4

President’s Message Dino Mercurio

6

Executive Director’s Message Lisette Mariner

8

Member News

10

Back to the Basics Terry Myers explains when you can claim a sales tax refund.

12

Keys to Insurance Insurance Agent of Record Kevin O’Connor tackles the timely topic of Dealers Open Lot coverage.

16

Be Prepared with FIADA Benefits

18

Legislative Update FIADA Lobbyist Sandra Mortham looks ahead to what dealers can do in the upcoming election season.

20

Improve Your Business by Having the Right Plan A top ten action list of best practices for successful dealers.

24

FIADA’s 2014 Annual Convention & Trade Show Registration is now open for the state’s premier dealer event. See the tentative schedule and use our registration form to save your spot.

26

A Look at Current Legal Issues The monthly round-up of federal and legal issues affecting auto dealers.

29

Don’t Miss Out On Your Free Lunch The July Town Hall Meeting is almost here. Make plans to attend and enjoy a complimentary lunch and education session.

30

Industry News

Send address changes to

FIADA • 1840 Fiddler Court Tallahassee, FL 32308 (850) 385-2712 • Toll Free: (800) 237-0448 Fax (850) 385-3251 • www.FIADA.com The Independent Dealer is a publication of: Florida Independent Automobile Dealers Association, 1840 Fiddler Court, Tallahassee, FL 32308 The magazine is published every month in Tallahassee and distributed to Florida new, used, wholesale and lease/retail car dealers. Advertising rates are available upon request. The statements and opinions expressed herein are those of the individual authors and do not necessarily represent the views of Independent Dealer or the Association. Likewise, the appearance of advertisers, or their identification as members of FIADA, does not constitute an endorsement of the products or services featured.

www.fiada.com

June 2014 — Independent Dealer — 3


FROM THE PRESIDENT

Plan to Be Prepared BY DINO MERCURIO, FIADA PRESIDENT

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’m sure most of you have heard the old adage, “Nobody plans to fail, they just fail to plan.” This is a very profound statement, and although it can have a slightly different meaning to each of us, I believe there has never been a truer statement uttered. Some things we need to plan for are obvious. It’s the unknowns and unforeseen things that come up that makes us think, “I wish I had a crystal ball!” Life throws us curves all the time, but the ones who are up-to-date, informed and educated are much more equipped to handle these curve balls when they arise. And, the best way to stay up-to-date, informed and educated in the used car industry is to get involved with the FIADA. FIADA is the only association that represents you and your rights day in and day out. There are many different ways to get involved and be a part of this great dealer association, the easiest being joining as an FIADA member. It doesn’t require anything more than submitting an application with your minimal dues payment, for your 12 full months of benefits to begin immediately! No homework, no assignments, no effort required. Just sit back and enjoy your monthly magazine full of information, the outstanding website you can access 24-7,

and an 800 number you can call to reach our fantastic staff to answer that burning question. You will even get a coupon book worth thousands of dollars in discounts and freebies at auctions and with industry vendors all over the state, covering the cost of joining many times over. As a member, you can also attend (for free!) any of our Town Hall or Quarterly Board Meetings to get hands-on, up to the minute information, meet vendors who can improve your business, and network with other dealers who have decades worth of knowledge and experience. Don’t fail to plan. Let the FIADA be your crystal ball and open your eyes to all the things going on in the industry today. Plan to attend the the next Town Hall and Board Meeting this summer. It will be at the beautiful Daytona Beach Resort at Ocean Walk Village, July 18-19. It’s right on the beach, so bring your family, bring the kids and make a summer fun weekend of it all while gaining the knowledge you need to be successful in today’s marketplace. Dino Mercurio FIADA President

Where’s Your Sign? Election season is approaching, which means candidates will be looking for a place to stake their signs. Help them out, along with the Association, by offering to display some at your dealership. It costs you nothing, but gains so much for the Association and the industry! Call FIADA at (800) 237-0448 to find FIADA-friendly candidates in your area.

4 — Independent Dealer — June 2014

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EXECUTIVE DIREC TOR’S MESSAGE

Let’s Get Ready Together BY LISET TE MARINER, EXECUTIVE DIREC TOR

I

t’s that time of year… Hurricane Season. In 2004, Florida faced four hurricanes. Charley, Frances, Ivan and Jeanne were among the costliest hurricanes to hit the US. There were 15 named storms that season, nine of which were hurricanes. Then, in 2005, we had Hurricane Katrina and in 2012 there was Hurricane Sandy. The 2013 Atlantic hurricane season was the first Atlantic hurricane season since 1968 to feature no storms of at least Category 2 intensity. Fortunately, the National Oceanic and Atmospheric Administration (NOAA) is predicting a near normal or below normal Atlantic hurricane season, with eight to 13 possible tropical storms and three to six possible hurricanes. As we prepare for what will hopefully be a not-so-turbulent hurricane season, there are still many precautions that should be done. Even if the storms we get do not have dangerously high winds, the rain alone from these storms can be damaging. You still need to make sure that your home and your business are ready for what may come.

one of your primary resources for technical assistance. As a member, you have the benefit of speaking to our General Counsel to answer questions such as, “I received a bankruptcy letter, what do I next?” or, “A customer bought a car, and now wants to return it, what am I obligated to do?” Whenever a technical or legal question comes up, call FIADA at (800) 237-0448. Prepare your staff by arming them with FIADA resources, too! FIADA offers abundant educational and networking opportunities. We have archived webinars, online courses, and multiple networking opportunities to learn from successful dealers and ask the experts. Our next networking opportunity is the Town Hall Meeting coming up on July 18 at the Daytona Beach Resort/Ocean Walk Village in Daytona. Then, of course, you can’t miss the Annual Convention, October 9-12 at the Omni Hotel & Resort ChampionsGate in Orlando. We always have great speakers and dealers from around the state that know the pitfalls of running a dealership in today’s market. Now that you’ve gathered your materials, the next step is to develop your plan. Include FIADA in you plan to succeed. Join a committee and guide the direction of the Association. Provide feedback to me about what’s keeping you up at night. If you’re not a member of the Association, joining is easy. Visit www.FIADA.com and click on membership or use the application on page 17 of this magazine.

Prepare yourself and your staff with FIADA resources such as archived webinars, online courses and multiple networking opportunities to learn from successful dealers and experts. Even when the forecast is mild, things can change quickly. Just as you would prepare the physical structure of your business for a storm, you should prepare the day-to-day operations of your business for success. The first step to any plan is to gather information. Create a directory full of the resources you need. Find the phone numbers, websites, contact info for the people who would be most helpful in different circumstances. For example, FIADA should be 6 — Independent Dealer — June 2014

Finally, practice your plan! Don’t wait for a storm to strike. Make sure that as a member of the Association you are utilizing your benefits every day. Visit www.FIADA.com and see what we have to offer. www.fiada.com


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MEMBERSHIP NEWS

New Members

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RENT A WRECK USED CAR RENTAL AND LEASING Laurel, Maryland Andrew Iatridis Sponsor: Amelia Tillman

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FIADA is your number one source for advice and information. Our network of industry veterans, professionals and consultants can help you find the answers you are looking for. Call us at (800) 237-0448 or go online to www.FIADA.com! 8 — Independent Dealer — June 2014

Renewing Members

MAY 2014

30+ Year Members M & W Auto Sales 20+ Year Members Harold D. Corey Auto Broker Manheim Tampa Tallahassee Auto Auction VIP Auto Sales 10+ Year Members Auto Select Automax Buyer’s Zone, Inc. Dick Moye Auto Sales, Inc. Gallagher Promotional Products J-Linn Motors Ted’s Auto Sales, Inc. Trinity Motors Van’s Cars & Trucks Under 10 Year Members ABCOA/Deal Pack Software Advanced Vehicle Modifications, Inc AFS Acceptance LLC Ashton Agency, Inc. AutoRaptor CRM BNM Enterprises, LLC Car Surplus Inc. CarBucks Cars.Com Central Florida Auto Wholesale, Inc. Central Florida Sales & Leasing Chaney’s Used Cars, Inc. Checkered Flag Auto Sales Cliff Shuler Auctioneers Dealer Funding, LLC Dennis LeVine & Associates, PA First Auto Sales Florida Cars USA Hinshaw & Culbertson, LLP Melbourne Auto Mart, Inc. Millennium Motors Ocean Auto Sales of Miami, Inc. Premier Motor Cars Ride-Away Handicap Equipment, Inc. Second Son Enterprises dba Victory Auto Sales South Side Kia Speedway Auto Sales Timeless Motors Vallejo Auto Sales Your Auction of Tampa Bay

Panama City, FL Indian Rocks Beach, FL Tampa, FL Tallahassee, FL Jacksonville, FL Saint Augustine, FL Palm Harbor, FL West Palm Beach, FL Pensacola, FL Longwood, FL Clearwater, FL Saint Petersburg, FL Sarasota, FL Brooksville, FL Jacksonville, FL Ocala, FL Ft Lauderdale, FL Winter Park, FL Providence, RI Saint Augustine, FL Mary Esther, FL Greenville, SC Chicago, IL Leesburg, FL Orlando, FL Avon Park, FL Lakeland, FL Titusville, FL Atlanta, GA Tampa, FL Bradenton, FL Miami, FL Tampa, FL Melbourne, FL Winter Park, FL Miami, FL Bonita Springs, FL Addison, TX Sarasota, FL Jacksonville, FL Winter Haven, FL Lakeland, FL Clewiston, FL St Petersburg, FL www.fiada.com


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BACK TO THE BASICS

Are You Leaving Money on the Table? If you end up reposessing or writing off a bad uncollectable debt you could be eligible for a refund of the sales tax. BY TERRY MYERS

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pportunity is where you find and recognize it. Whether you recognize it, are ready for it and take advantage of it or not is up to you. Agree? One opportunity where many Buy Here-Pay Here dealerships leave money on the table is not taking a refund from the Department of Revenue when a vehicle is repossessed.

Take this example. You sold me a $15,000 automobile, took a $5,000 vehicle in trade and collected $650 in state sales tax and county discretionary surtax. There is a contract for 24 months, with monthly payments due. Sales tax is due at the time of the sale and you remit these funds on your monthly report. Eight months into the contract, I default and you repossess the vehicle. The vehicle is titled in the name of the dealership. Your dealership is entitled to a refund of unearned sales tax, linked to the unpaid portion of the contract. To get the refund, you must obtain Department of Revenue form DR-95B, complete the requested questions and do the math. The resulting answer is how much unearned sales tax dollars the dealership may take back. Those funds are recaptured on Line 6, Less Lawful Deductions, of the monthly 10 — Independent Dealer — June 2014

DR-15R report. You must claim these funds within twelve months of the repossession or leave the money on the table. Remember, though you must have supporting documentation to back up everything from the sale through the repossession and retitling of the vehicle, during an audit with the Department of Revenue. Here is another way the same scenario could go down. Eight months into the contract, I default and you are not able to find the vehicle to repossess it. You write it off against your federal taxes as a bad uncollectable debt. Again, your dealership is entitled to a refund of unearned sales tax. Just as before, to get the refund you must obtain Department of Revenue form DR-95B, complete the requested questions and do the math. The resulting answer is how much unearned sales tax dollars the dealership may take back. Those funds are recaptured on Line 6, Less Lawful Deductions, of the monthly DR-15R report. As I said earlier, you must claim these funds within twelve months of the bad debt write off or leave the money on the table. Again, you must have supporting documentation to back up everything from the sale through the Bad Debt write off, during an audit with the Department of Revenue.

Same story, but one more scenario. At the eight month mark the dealership takes the vehicle back and refunds the purchase price and the sales tax. The dealership is able to take back the sales tax on Line 6, Less Lawful Deductions. There is a warning in this case, however. If the vehicle has gone through the titling process, you are buying the car back. This is not a refund. You need to ask the Department of Revenue about this process before applying for the Line 6 Less Lawful Deduction. Florida Administrative Code 12A1.012, Repossessed Merchandise and Bad Debts contains the legal language relevant to this topic. It is the responsibility of the dealership to properly interpret the code. Consultation with your legal counsel is always advisable. Also, go to a local Department of Revenue office and talk to someone across the desk about this topic. They are as interested in helping you benefit from this code as you are. Department of Revenue’s form GT-400400 is also available at www. myflorida.com/dor under the forms and publications link. It contains valuable information relevant to this topic and many others. To truly report and benefit, you need to have the proper knowledge. So, are you leaving money on the table? Articles are the opinion of the author and are not intended to be regulatory, legal or accounting advice. The intent is to share thoughts and concepts that help the business owner(s) find new and perhaps revisit, ways to be as successful as they are capable of being. Terry can be reached at (727) 804-7375. Email: tmyers@ floridaautodealerschool.com. Feedback is appreciated and encouraged. Copyright 2014, Terry LB Myers, author, lecturer, FIADA instructor, FADS owner/instructor. www.fiada.com


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KEYS TO INSURANCE KEYS TO INSURANCE

Insurance Predictions for Dealers Open Lot: It Pays theKnow New Year to if You’re Covered BY KEVIN O’CONNOR, INSURANCE AGENT OF RECORD

B I

y the time this magazine goes to print, we will beannounce in the 2014 season. The so amofficially excited to thehurricane resurrection of “Keys to called “experts” are calling for a relatively quiet Insurance,” a column I wrote for many years in thisyear. On magazine face value,throughout that’s great the news! But,and theup reality that over 1990s untilis2005. The the last 13 years the predictions only been column touched on expert the subjects relatinghave to the insurance correct half the time. Results those certainly needs ofabout the non-franchised motor like vehicle dealer. don’t offer this insurance guy too much comfort. Starting this month, we will be doing a quarterly edition While we’ve hadWe noplan storms make landfall the last nine of the column. to discuss subjectsinsuch as risk years, the pessimist in me can’t help but think we’re due. management ideas to help reduce your insurance costs and Regardless of what youclaims, believe,changes any prudent businessmarket needs eliminate unnecessary in insurance to start thinking about preparedness and risk management conditions, trends in pricing and coverage availability, new plans so in the event we do get hit, we’re ready. products available to the dealer industry and more. The floods inathe Panhandle generated a number of ThisApril past year was challenging year in our business, claims and made me think about how important it is that especially here in Florida. A new “wind modeling” system you understand your coverage and how it will work after was implemented which completely changed the way a loss. A number of dealers spoken have had their carriers look at we’ve certain areas.to This new system lots flooded in that storm only to find out they had no identified that non-coastal areas had coverage in place. more hurricane exposure than was

previously believed and pricing Over the last 10 years, insurance companies been of policies werehave revised limiting their weather exposure in Florida. Many carriers accordingly. The have been excluding or, at the very least, limiting wind and claims from

2012’s Hurricane Sandy had a devastating effect on the Dealers Open Lot insurance marketplace. As a hail coverage. This “tightening” in the market result, worsened the insurance after Superstorm Sandy. Even though Sandy didn’t carriers are happen now in Florida, the storm’s effectlooking on the more reinsurance market closely at floodwas felt nationwide. An estimated 500,000 vehicles were lost in exposure than ever before making the storm, mostly due to flood. Insurance carriers hadn’t paid much attention to flood exposure prior to this event, 10 — Independent January 2014 Many carriers but since then, it’s aDealer whole—new ballgame.

that used to only look at the distance to the water as the determining factor are now looking at flood zones and it difficult to find policies on dealers that never had an excluding flood coverage or putting crippling deductibles issue in past years. These changes caused a number of on the policy. insurance companies to withdraw from the Florida market or limit what they offer causing a supply and demand issue This new paradigm shift in the way insurance companies which subsequently raised rates. On the positive side, the offer coverage forces you to carefully examine your insurance industry has record surplus capital thanks in policy so you aren’t surprised if after a claim the coverage large part to lower than expected catastrophe losses over isn’t there. The following are the most critical areas to the last few years and increased investments yields. Most investigate and questions to ask yourself. of the insurance industry analysts expect the trend of increasing rates to slow or even reverse in the near future. What type of coverage do I have? Unfortunately there are no crystal balls to tell us what to The insurance needed to cover a dealer’s inventory expect in 2014. All we can do is keep a close eye on the is typically called “Dealers Open Lot.” There are industry and do our best to keep the readers of this column several specific forms that can be used. Historically, ahead of the curve. “Comprehensive” and “Specified Perils” have been the norm. These forms are designed to cover weather related On a personal note, I wanted to thank the FIADA Board loss in addition to fire, theft, vandalism and the like. of Directors for the vote of confidence in electing us their Another form that was rarely seen prior to the last several Agent of Record. Our team of insurance professionals years is called “Fire and Theft.” This form is showing up specialize in your industry and make it our job to know quite often since it eliminates the weather coverage. While how your business works and understand what your the carrier is trying to eliminate the weather exposure, dealership needs to best protect your assets. We are this form also eliminates vandalism. Of all the options out available for questions from any association member there, this one is the least desirable. whether they are clients or not and we will do our best to answer those questions in a completely impartial manner. Another option you may see is where the Comprehensive or Specified Perils We hope that Keys to Insurance is an informative and are provided, but with an endorsement interesting column and proves to the readers that insurance (often times buried in the policy) can be fun. specifically excluding wind, hail and/or flood. While this is a better option than “Fire and Theft,” it’s very tricky to find the endorsement Kevin O’Connor of Dealers Insurance Services, Inc. is the and dealers aren’t always made aware of its presence. FIADA Insurance Agent of Record. If you have insurance related questions, contact FIADA at (800) 237-0448 or visit What is my deductible? the DIS website at www.dealersinsurance.com. This used to be an easy answer but has also become very confusing in recent years. Historically the standard

When it comes to weather-related claims, it is more important than ever to understand your coverage and how it will work after a loss.

12 — Independent Dealer — June 2014 FIADA Jan 2k14.indd 10

www.fiada.com Continued on Page 14. www.fiada.com

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April 2014 — Independent Dealer — 13


DEALERS OPEN LOT continued from Page 12.

structure for deductibles as they related to weather exposure was a “per vehicle” deductible most often of $500 or $1,000, and then an aggregate of five times the per vehicle deductible. The term aggregate simply means the most a dealer would have to pay in the event of multiple vehicles being damaged. If you had a $1,000 per vehicle deductible, the most you would pay out of pocket after a covered loss was $5,000. While these terms are still available, it is becoming very common to see policies written on a “no aggregate” basis. When this happens, your post storm deductible would be $1,000 per vehicle but there would be no cap. If you had 50 cars on the lot, you could potentially be out of pocket $50,000. To further confuse the matter, some companies are applying specific dollar amounts to specific types of loss. You may see a $1,000 deductible with a $5,000 aggregate on Comprehensive but there may be a limiting endorsement that says the weather related loss is $500 per vehicle with no aggregate. Unfortunately, these are all free form endorsements and there is really no standard to rely on. The “Coinsurance” trap One of the least understood parts

of Dealers Open Lot coverage is the coinsurance provision. Every policy I’ve seen in my 28 years of experience doing this type of insurance has coinsurance and 90 percent of the dealers we talk to have never had this concept explained to them. Not understanding it can cause huge penalties after a claim. Dealers Open Lot coverage requires that a dealer purchase 100 percent insurance to value. In simple terms, if you own $200,000 in vehicles, you must purchase $200,000 in insurance to avoid the penalty. Almost daily I hear dealers tell me “I only need $100,000 of coverage because that’s all my floor planner wants” or “I don’t want to cover the entire inventory since there’s no way all the vehicles will be damaged at the same time.” Unfortunately, many agents don’t explain the dangers of this either because they don’t understand it themselves, or they are just trying to get the business and don’t want to upset the applecart. The formula to calculate a coinsurance penalty is simple: did over should. In the event of a claim, the insurance carrier takes the dollar amount of what you “did” buy for coverage and divides it by the amount that you “should” have bought for

coverage. That percentage is the amount they pay. Let’s look at a simple example: A dealer elects to purchase $100,000 of Dealers Open Lot coverage. He has a loss on a $10,000 vehicle. The insurance company asks to see his inventory list at the time of the loss and he had $200,000 (both owned and floored) on that date. The insurance company calculates what he did have, $100,000, and divides it by what he should have had, $200,000; $100,000 divided by $200,000 is .50. He is currently insured for 50 percent and still has a $1,000 deductible. Imagine how you’d feel when you get a check for $4,000 for your $10,000 vehicle! How do you avoid these problems? Make sure you buy from a reputable agent and ask a lot of questions. It can be difficult these days to navigate the different plans being offered. While your agent and the proposal they offer should be a good starting point, there is no substitute for you actually reading thoroughly through your policy and becoming educated. Kevin O’Connor of Dealer Insurance Services, Inc. is the FIADA Insurance Agent of Record. .

www.niadaconvention.com 14 20142014 14— —Independent IndependentDealer Dealer— —June February

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FREE TRAINING

As a FIADA member you will have free trainings and networking opportunities at FIADA’s Quarterly Town Hall Meetings and Board of Directors Meetings. Discounted training is available for FIADA members at our Annual Convention.

TECHNICAL ASSISTANCE

Who ya gonna call? All FIADA members have unlimited access to FIADA’s Technical Assistance Line – Call 800.237.0448 with your regulatory, legislative and legal questions to receive assistance from FIADA’s General Counsel

INDEPENDENT DEALER MAGAZINE

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FIADA Members have access to online Members’ Only Resources including the Dealer Training School Manual, Repossession Manual, Red Flags Rule Templates, Safeguards Rule Information, and more.

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18— —Independent IndependentDealer Dealer— —August 2013 18 June 2013 www.fiada.com 18 — Independent Dealer —January 2014

www.fiada.com www.fiada.com May 2014 — Independent Dealer — 17 www.fiada.com


L E G I S L AT I V E U P D AT E

Looking Ahead BY SANDRA MORTHAM, FIADA LOBBYIST

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ou heard about the registration fee reduction last month, but here’s one more tax cut for Floridians. On the last day of session, the Legislature approved a $105 million tax cutting package (HB5601) and Governor Scott promptly signed it into law on May 12. The majority of the package cuts are encompassed in the three sales tax holidays: • • •

Hurricane Preparedness Sales Tax Holiday, May 31 through June 8, 2014 Back to School Sales Tax Holiday, August 1-3, 2014 Energy Star/Water Sense Appliances Sales Tax Holiday, September 19-21, 2014

With hurricane season here we know that Election Day is right around the corner so soon we’ll begin to see the barrage of campaign commercials and signs. As we begin to look ahead into our next election period, I encourage you to do your part. Be informed, make your voice heard, and support our legislative efforts!

Resort/Ocean Walk Village in Daytona. Here, we will continue the conversation about what happened during this legislative session, and we will strategize for next year. MAKE YOUR VOICE HEARD There are plenty of ways to communicate with your legislative representative, the FIADA Board, and other Florida dealers. Put a campaign sign in your yard supporting the candidates who are passionate about the independent automobile dealer industry. If you don’t know who that might be, please contact us and we’ll let you know. Consider joining one of the FIADA Committees so you can express your opinion about the issues that are affecting FIADA members. Together, we can ensure that all of the business interests of Florida used car dealers are protected. SUPPORT OUR LEGISLATIVE EFFORTS One person can certainly make a difference, but it is our collective efforts that make the greatest impact. Consider making a contribution to the FIADA PAC fund so we can hit the ground running in 2015. Our FIADA PAC fund is the financial source behind all of our legislative work, and small contributions from each Florida dealer can really add up!

Election season is right around the corner. Do your part by being informed, making your voice heard and supporting the FIADA’s legislative efforts. BE INFORMED Stay up-to-date with the legislative issues that affect your dealership. Have a question about a legal or compliance issue? Call FIADA to speak with our attorney, or, better yet, meet us in person! Plan to attend the next Town Hall meeting coming up on July 18 at the Hilton Daytona Beach 18 — Independent Dealer — June 2014

At the time of this article, the Governor has not yet received the DMV legislative package (HB7005) that includes the reinstatement of the Surrender Stop. Be sure to watch for FIADA email, e-newsletters, and other updates as we expect the Governor to receive the package within the next few weeks. We thank you for doing your part and taking the time to support our legislative efforts. www.fiada.com


SUPPORT THE FIADA PAC FUND! Your PAC Contribution helps spread awareness and gain support of issues affecting independent dealers in the state’s capitol.

CONTRIBUTION INFORMATION

PAYMENT INFORMATION

Contributor’s Name:

Name on Card:

Dealership/Company:

Card number:

Street Address, City, State, Zip:

Exp Date: Sec. Code:

q

Check q

Credit Card (one time contribution)

q

Monthly Credit Card Contribution (until cancel)

q

$500

q

$250

q

$25

q

_________

$100

q

q

Billing Phone: $50

Billing Address

Credit Card Information: q

Visa

q

MasterCard

q

AmEx

q

Discover

Authorized Signature

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Make your check payable to FIADA-PAC and mail to: FIADA • 1840 Fiddler Court • Tallahassee, FL 32308 If making payment via credit card, you may fax your contribution form to 850.385.3251

www.fiada.com

June 2014 — Independent Dealer — 19


D E A L E R O P E R AT I O N S

Improve Your Business by Having the Right Plan A top 10 list of the best business practices successful dealers should follow. BY JENNIFER FINLAY

R

unning a successful dealership takes time, talent and investment. Here is an action plan on how you can get your business where you want it to go.

1

INVEST IN YOUR BUSINESS Remember, investing in your business does not just mean buying inventory. There are many ways to invest in your business and increase its growth potential. One of the most important is investing your time, as the owner / operator. This sounds like a simple concept, but I know from experience it is difficult to schedule time way from everyone and day to day business. Schedule time outside of your dealership at least once a month. Take this time to reflect on the previous month. Did you make money? Did you lose money? Was there a turnover in staff? Were there any customer issues and so on. What if anything could you do to improve any one of those situations? Make notes and deadlines for yourself on the calendar for the upcoming month. Stick to your plan and you will see your operations becoming more streamlined and productive in just a few months.

2

GET INVOLVED IN YOUR COMMUNITY Your local Chamber of Commerce is a great place to start. Many offer more services, resources 20 — Independent Dealer — June 2014

and networking opportunities than people know. Participate in community events whether it is sponsoring a little league team, helping with a food or toy drive, or donating to your local animal rescue. Not only will these all come with advertising possibilities, it promotes the personality of your business. It makes it known you are the type of business that people want to do business with.

3

PAY MORE FOR YOUR DETAILING AND RECON THAN THE AVERAGE DEALER At first this may not seem like a good idea, but believe me it is. Think about how much time is invested in buying inventory. How many auctions did you have to travel to in order to get the inventory you need for your lot? For many owners this is their main job, to keep the inventory coming in so their sales people always have enough to sell. The one thing that stands between you purchasing the vehicle and your customer buying it is what happens in the detail department. This could make or break how hard you worked to get that piece of inventory. A perfectly detailed, clean smelling vehicle is the first step in getting a customer hooked. So, find a good, experienced detailer and pay him or her competitively.

4

DON’T BE AN ABSENTEE OWNER Know what is going on in your store. Have the ability to step into the role of any of your staff. Maybe you won’t be able to do their job as efficiently as they do, but at least know the basics in case you are ever faced with a situation where you need to. This helps also in keeping up with internal changes and procedures that will naturally happen in the course of business.

5

TREAT YOUR MONTHLY CLOSEOUT LIKE AN AUDIT There is no such thing as keeping too many records. And it’s a lot easier to keep track of by the month than to have to go back and figure out why something happened after the fact. Look at your month end closeout and ask yourself “If I have to revisit this in two years for a Department of Revenue Audit is everything accounted for?”

6

THE DMV IS NOT YOUR ENEMY Contrary to what most dealers think, your local DMV and your regional compliance officer for your location are there to help you. They are not “out to get you,” so to say in an audit. Get to know your compliance officer and ask questions. They will actually give you a list of things they review in an onsite audit. Go over it. Understand the records they will want to see and make sure you have them in place. This keeps you in compliance and makes their job easier as well. It’s a win-win situation.

7

ALWAYS APPRECIATE YOUR STAFF Over the years I have seen so many very dedicated and hardworking employees over time start to lose their drive due to feeling Continued on Page 22. www.fiada.com


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June 2014 — Independent Dealer — 21


TEN TIPS continued from Page 20

like they are being taken for granted. If you are lucky enough to have employees that will go the extra mile for you, make sure they know how much you appreciate them. A little bit will go a long way. It doesn’t always have to be a bonus or a raise. It could be something as simple as a restaurant gift card, tickets to the baseball game, or even just saying “I know you stayed an hour and half late last night, just want you to know I really appreciate it.” This simple management tool will keep those who work hard for you pushing forward.

8

GET A LOCAL MARKET REPORT There are companies that will, for a small fee, send you what is called a Market Report. This report will contain every independent dealership in your county, how many cars they sold, what cars they sold and

who the lender was. This can be very helpful. Know who your competitors are, what they are doing and who they are selling to. This report will also list the top selling cars, if you know what vehicles are selling the most, you will know what inventory to buy.

9

RESEARCH YOUR ADVERTISING Ask your customers how they found you. You are spending money every month to bring people to your dealership. If you know what advertising is reaching the most potential customers you will know how to fine tune your advertising plan and get the most out of what you are spending.

10

NEVER STOP LEARNING FOR YOURSELF AND YOUR STAFF “Knowledge is Power” I like to say. It

is absolutely critical to your business to continue education. There are many resources out there waiting for you to take advantage of. Whether it be a consulting company, the Small Business Administration, your local SCORE, or the FIADA. There is new information out constantly entering the flow. This is a fast paced growing industry and it’s your job to keep on top of changing laws, trends and business practices. In addition to the obvious benefits, this is a huge motivational tool when it comes to your staff. Jennifer Finlay has worked in the auto industry for 17 years, including one of the largest Buy Here-Pay Here dealerships in Volusia County. She is a licensed instructor and teaches one of the FIADA pre-licensing classes for new dealers.

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C

ome be a part of the ultimate dealer experience of the year at the 2014 FIADA Annual Convention. This year’s theme: Pirate Party! Arrrghh...Don’t forget ye eye patches, booty, pirate garb and have a swashbuckling good time with the “best of the best” as Florida’s top dealers come together for a weekend of education, networking and fun.

TENTATIVE SCHEDULE THURSDAY, OCT. 9, 2014 3:00 - 7:00 PM

Registration Open

6:30 - 8:30 PM

Welcome Reception

FRIDAY, OCT. 10, 2014 7:30 AM - 4:00 PM

Registration Open

8:00 - 9:00 AM

Breakfast

9:00 -10:00 AM

Opening Keynote

10:00 -10:15 AM

Member Meeting/Elections

10:15 -10:30 AM

Coffee Break

10:45 -11:45 AM

Workshop

12:00 -1:30 PM

Networking Lunch

1:45 -2:45 PM

Workshop

3:00 -4:00 PM

Workshop

5:00 -9:00 PM

Exhibit Hall Opening/

Family Fun Night

SATURDAY, OCT. 11, 2014

24 24 — — Independent IndependentDealer Dealer — — June May 2014

7:30 AM - 3:00 PM

Registration Open

8:00 - 9:00 AM

Breakfast with Exhibitors

9:00 -10:00 AM

Workshop

10:15 -11:45 AM

Keynote & Awards Ceremony

12:00 - 2:30 PM

Lunch with Exhibitors & Exhibitor Giveaways

2:45 - 3:45 PM

Workshop

3:00 - 5:00 PM

Exhibitor Breakdown

4:00 - 5:30 PM

Workshop

5:30 - 7:00 PM

Closing Reception

7:00 - 9:00 PM

Past Presidents Dinner www.fiada.com


2014 FIADA Annual Convention Registration Form COMPANY INFORMATION

Company:___________________________________________________________________________________________________________ Address:__________________________________________________ City, State, Zip:_____________________________________________ Phone:___________________________________________________ Fax:______________________________________________________ E-mail:___________________________________________________ Website:__________________________________________________

REGISTRATION INFORMATION FIADA MEMBER DISCOUNTED REGISTRATION RATES

EARLY BIRD (2/1 - 8/31)

REGULAR (9/1 - 10/3)

ON-SITE (10/4 - 10/11)

[

] $249

[

] $299

[

] $349

Badge Name:___________________________________________________________

[

] $195

[

] $195

[

] $195

Badge Name:___________________________________________________________

[

] $195

[

] $195

[

] $195

[

] $100

[

] $100

[

] $100

[

] $99

[

] $124

[

] $149

Badge Name:___________________________________________________________

[

] $299

[

] $349

[

] $399

Badge Name:___________________________________________________________

[

] $195

[

] $195

[

] $195

Badge Name:___________________________________________________________

[

] $195

[

] $195

[

] $195

[

] $100

[

] $100

[

] $100

[

] $124

[

] $149

[

] $175

MEMBER

FULL ACCESS PASS Badge Name:___________________________________________________________

ADDITIONAL FULL ACCESS PASS (Available with purchase of Full Access Pass)

SPOUSE FULL ACCESS PASS (Available with purchase of Full Access Pass) Badge Name:___________________________________________________________ EDUCATION PASS (Does not include meals) Badge Name:___________________________________________________________

NON-MEMBER REGISTRATION RATES

FULL ACCESS PASS NON ADDITIONAL FULL ACCESS PASS (Available with purchase of Full Access Pass) MEMBER

SPOUSE FULL ACCESS PASS (Available with purchase of Full Access Pass) Badge Name:___________________________________________________________ EDUCATION PASS (Does not include meals) Badge Name:___________________________________________________________

FULL ACCESS AND SPOUSE FULL ACCESS PASSES includes all meal functions, seminars and exhibit hall access and is eligible for continuing education credit. Additional Full Access passes and Spouse pass are only available with a Full Access registration. Valid FIADA membership required for FIADA member registration rates. CHILD REGISTRATIONS AVAILABLE Contact FIADA at (800) 237-0448 for details and to register.

TOTAL:

$

PAYMENT METHOD [

] I have enclosed a check made payable to FIADA

[

] I will be using a credit card

Name (as it appears on card):_____________________________________ Company:______________________________________________ Credit Card Billing Address:______________________________________________________________________________________________ Credit Card Number:________________________________________________________________

Exp Date:_________________________

Authorized Signature:_______________________________________________________________ CC Security Code:___________________ CANCELLATION POLICY: If cancellations are received in writing before 5pm on Sunday, September 8, 2014, we will refund your registration fee. If cancellation is received between 9/9/14 and 9/30/14, we will refund your registration fee less a $25 processing fee. Fees cannot be refunded for registrations cancelled after 10/1/14 or for no-shows. PHOTO/VIDEO RELEASE: By registering for the 2014 FIADA Annual Convention, I hereby grant permission to use any and all photographic imagery and video footage taken of me at this event and activities pertaining to this event, without payment or any other consideration. I understand that such materials may be published electronically or in print, or used in presentations or exhibitions.

HOTEL INFORMATION: Omni ChampionsGate. Hotel stay is separate from convention registration. Reservations must be made BEFORE SEPTEMBER 8, 2014 to qualify for group discount of $149 per night (plus tax) For reservations call (800) THE-OMNI/(800) 843-6664. www.fiada.com Mail: FIADA, 1840 Fiddler Court, Tallahassee, FL 32308

Fax: (850) 385-3251

June 2014 — Independent Dealer — 25 Online: www.FIADA.com Call: (800) 237-0448


LEGAL ROUND-UP

A Look At Current Legal Issues BY THOMAS B. HUDSON AND NICOLE FRUSH MUNRO, HUDSON COOK, LLC

A monthly collection of selected legislative and regulatory highlights, and a recap of some of the many auto sale and financing lawsuits followed each month. COMPLIANCE TIP The Consumer Financial Protection Bureau is sending confidential Civil Investigative Demands to independent car dealers. If you get one of these CIDs, one of the things that the CFPB will want to see is your comprehensive written Compliance Management System. If you don’t have such a system, now’s the time to put one in place. If your general level of compliance is woefully deficient (if, for example, you don’t have a Safeguarding Policy in place or don’t send adverse action notices), now’s the time to consider selling the dealership and buying a Subway franchise. FEDERAL DEVELOPMENTS On April 9, the CFPB announced an enforcement action against Bank of America, N.A. and its subsidiary, FIA Card Services, N.A., for unfair billing practices related to their identity protection credit card add-on products, which promised to monitor customer credit and alert customers to potentially fraudulent activity, and for deceptive marketing related to two credit card payment protection products. Under the consent order obtained by the CFPB, (1) B of A will be prohibited from marketing any credit protection or credit monitoring product until it submits a compliance plan to the CFPB; (2) consumers will no longer be billed for these add-on products if they are not receiving the promised benefits; (3) the Bank must provide approximately $727 million in relief to consumers harmed by the practices related to the credit card add-on products; and (4) the Bank will pay $20 million to the CFPB’s Civil Penalty Fund. The Office of the 26 — Independent Dealer — June 2014

Comptroller of the Currency has also been investigating the alleged unfair billing for identity theft protection products and separately ordered a $25 million penalty for these practices, in addition to those ordered by the CFPB. The action should be noted by dealers selling ancillary products in connection with car financing – the Bureau is especially interested in this area. On March 31, the CFPB released its 2013 Consumer Response Annual Report. According to the report, consumer complaint volume in 2013 increased 80% from 2012 - 163,700 complaints in 2013 compared to 91,000 in 2012. Mortgage-related complaints accounted for 37% of the 2013 complaint total, almost doubling the number of complaints about the next-closest industry (debt collection at 19%). Vehicle financing and leasing complaints fall into the category of consumer loans, which accounted for 3% of all complaints.

extend “consumer credit” within the meaning of the MLA, but instead were pawnbrokers operating under state pawnshop statutes. The court noted that the MLA does not define “consumer credit transaction” by deferring to state law definitions of those terms. The court also noted that the MLA preempts state law inconsistent with the MLA. It does not matter that the state law would categorize the transactions as “pawns” rather than “loans.” According to the court, what matters is that each of the plaintiffs deposited a vehicle title with a defendant as security for the payment of a debt. If the debt is not paid, then the plaintiff loses the title to the car and the car. Even though these transactions may not be considered “credit” transactions under state law, the court found that they are “consumer credit” transactions within the meaning of the MLA. The court concluded that the plaintiffs could pursue their claims as a class. See Cox v. Community Loans of America, Inc., 2014 U.S. Dist. LEXIS 38089 (M.D. Ga. March 24, 2014).

LITIGATION Title Loan Transactions Covered by Military Lending Act: Active duty military servicemembers brought a class action suit against several vehicle title loan companies based on the companies’ alleged violation of the Military Lending Act. The plaintiffs moved for class certification. After determining that the pre-2013 MLA implicitly authorizes a private right of action for damages, the federal trial court concluded that the plaintiffs’ title loan transactions were covered by the MLA. The defendants argued that they were not “creditors” who

Dealer Liable under Ohio Consumer Sales Practices Act for Failing to Disclose Unibody Damage to Used Car Regardless of “As Is” Clause: Buyers sued the dealer who sold them a used car after they found out that the car had sustained unibody damage. The dealer bought the car at an auction and signed a sales receipt that disclosed the unibody damage, but claimed that he did not read the receipt before signing. The purchase agreement between the dealer and the buyers waived all warranties with a conspicuous “as is” clause on its face. The buyers sued for violations of Ohio’s Consumer Sales www.fiada.com


Evidence of Oral Statements Made by Lender’s Agent Inadmissible to Support Claim for Violation of TILA Insurance Disclosure Requirements: A lender made a loan to a couple secured by a lien on their car. The note and security agreement included a charge for “Limited Physical Damage Insurance,” which the borrower must pay unless the borrower obtained insurance from a provider acceptable to the lender. The borrowers claimed that they questioned this insurance charge and showed proof of their existing insurance to the lender’s agent, but the agent told them that the insurance charge was required, so they paid the charge. When the buyers filed a Chapter 13 bankruptcy petition, the lender filed a secured claim. In response, the borrowers argued that the note and security agreement violated the Truth in Lending Act. Regulation Z requires charges for insurance against loss or damage of property to be included in the finance charge unless specifically excluded. An exclusion exists for insurance premiums if certain conditions are met, including the condition that “the insurance coverage may be obtained from a person of the consumer’s choice, and this fact is disclosed.” The borrowers alleged that the oral representations made by the lender’s agent rendered the insurance disclosure unclear. They also argued that by taking the voluntary choice from them, the lender violated Reg. Z. The U.S. District Court for the Northern District of Alabama declined to consider the oral extraneous evidence to determine whether there

was an ambiguity in the insurance disclosure required under TILA. The court explained that no extraneous oral evidence can be presented by a plaintiff to prove that the defendant gave the impression that insurance was required, except in the case of illiteracy, fraud, or duress. See White v. Superior Financial

Services, LLC, 2014 U.S. Dist. LEXIS 31811 (N.D. Ala. March 12, 2014). Tom (thudson@hudco.com) and Nikki (nmunro@hudco.com) are partners in the law firm of Hudson Cook, LLC. For information, call 410-865-5411 or visit www.counselorlibrary.com.

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Practices Act, among other claims. The trial court found that the dealer committed a violation of the CSPA and awarded the buyers treble damages and attorneys’ fees. The appellate court affirmed, finding that the “as is” clause was only effective to waive warranty and contract claims, not statutory CSPA claims, and also finding that the dealer committed one violation of the CSPA by not disclosing the unibody damage. See Hamilton v. Ball, 2014 Ohio App. LEXIS 1054 (Ohio App. March 19, 2014).

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Choices. That’s the advantage with Dealers Insurance Services. No matter what the insurance marketplace throws at you, we’ve got your back. DIS has spent the past 20 years building solid relationships with the most respected carriers in the industry while at the same time always looking for the most current and innovative options to these established programs.

28 2014 28— —Independent IndependentDealer Dealer—January — October 2013

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Come to the next Town Hall Meeting and have lunch on us.

Stay for the Board Meeting!

Lunch generously provided by Auto Data Direct

The quarterly FIADA Board of

July 18, 2014 • 10am - 2pm

Directors meetings always follow the Town Hall event, and are free

Daytona Beach Resort/Ocean Walk Village 100 N Atlantic Ave, Daytona Beach, Florida, 32118

and open to all dealers. Join us on Saturday, July 19 at 9 a.m. at the Daytona Beach Resort to help

FIADA hosts these quarterly meetings around the state as a free opportunity to network with other dealers and learn about the industry. The education session includes Q&A time where you can get answers to your technical and regulatory questions.

shape the future of your industry.

Register Online Now at www.FIADA.com

   

Franchise Issues Buy/Sell Transactions Licensing Consumer and Business Litigation

   

Legal and Regulatory Compliance Real Estate Employment Law and Workers Compensation Government Relations and Election Law

305-929-8500 • www.kb-attorneys.com MIAMI 18851 NE 29 Ave, Suite 303 Aventura, FL 33180 p: 305-929-8500 TALLAHASSEE 105 W. 5th Ave Tallahassee, FL 32303

p: 850-391-5060

www.fiada.com

June 2014 — Independent Dealer — 29


INDUSTRY NEWS FIADA’s On-Demand Webinar Library Continues to Grow

Paymaxx Pro Integrates with Cars*Plus DMS™

FIADA Members have access to all of the past webinars in the current On-Demand library at no cost. Just log-in through www.FIADA.com and watch some of the latest titles, including:

Paymaxx Pro, the national automotive retail merchant services and payment processing firm, has integrated its payment processing services with Cars*Plus DMS (Radiant Concepts, Inc.) giving dealers the ability to efficiently provide consumers with more options for payments while simultaneously reducing costs and fees for dealers using this dealer management system. Cars*Plus DMS is a reliable and innovative management software tool for Buy Here Pay Here Dealerships that serves hundreds of dealers across the states of Texas, Arkansas, Louisiana, Mississippi and Oklahoma. “We are very excited about the partnership. We believe this integration is a perfect fit for dealers looking to provide customers access 24/7 as well as boosting collections through integrated solutions. The Paymaxx Pro interface will have a significant impact by eliminating the geographical gap that had previously defined the BHPH model.” says Candy Wright, VP Radiant Concepts, Inc. “In today’s marketplace, it is all about providing a robust menu of payment options for consumers while improving operational efficiencies and reducing overhead at the dealer level,” said Paymaxx Pro President Chris Leedom. “We are excited about the strong partnership formed with Cars*Plus DMS and look forward to generating savings for the Cars*Plus DMS community of dealers.” This integration permits dealers to process web payments and automatically synchronize them between Paymaxx Pro and Cars*Plus DMS. At the same time, Paymaxx Pro offers retailers among the lowest costs and fees for merchant services in the industry. “All a dealer has to do is select Paymaxx Pro as their merchant services provider through Cars*Plus DMS” Leedom said. “This eliminates the need to use multiple software providers and eliminates double postings, thus saving labor costs. Dealer clients also have the ability to set up recurring automatic payments, both ACH and credit card which are often requested by consumers.”

It’s a Popularity Contest: Simple ways to Drive Traffic to your Web Site and Inventory by Tracy Amato Attendees will learn: • What factors attribute to obtaining higher search engine rankings • Tips on how optimize content on your website • The power of YouTube and blogging • How social media impacts your search ranking • The importance of a mobile presence • How listing inventory on multiple marketplaces like eBay, Craigslist, and classifieds will increase website traffic Don’t Get Stuck in the Mud of Today’s Regulatory Landscape by Rob Sickles Attendees will learn about: • Federal and State regulatory issues from an expert attorney • Consumer Financial Protection Bureau • Florida Attorney General • Florida Department of Financial Services • Florida Department of Motor Vehicles Hot Topics in the Payments Industry: Plain Talk on PCI Compliance and Influencing Consumer Behavior with Jon Leedom, Melissa Leedom and Dan Steiner of the Leedom Group Attendees will learn: • PCI Compliance • Convenience Fees • Surcharge Rules This course is free for FIADA Members and only $10.00 for Nonmembers.

FLHSMV Update: Revisions to Form HSMV 82994 Recently, the Department revised the front page of form HSMV 82994, Motor Vehicle Title Reassignment Supplement, with a revision date of 04/14. The Reassignment Information section includes new fields for selling price, co-purchaser’s printed name, and address if applicable. The Perjury Clause section includes fields for the printed name and signature of a co-seller if applicable. Additionally, some of the fields have been reorganized. You can read the memo and get a copy of the form online at www.FIADA.com. 30 — Independent Dealer — June 2014

www.fiada.com


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2013-2014 FIADA EXECUTIVE COMMITTEE:

DINO MERCURIO President Independent Credit, Inc. West Palm Beach, FL (561) 686-8673

JIM WINTERICK, SR. CHRISTOPHER LEEDOM PHIL RISLEY Senior Vice President Chairman of the Board Secretary Gulfstream Motor Credit AutoMaxx Cars & Credit of Jacksonville Miami, FL Sarasota, FL Jacksonville, FL (305) 253-2335 (941) 309-1111 (904) 616-4074

LISA COMPAGNO Regional Vice President Palm Tree Auto Sales Stuart, FL (772) 288-2099

FRANK FUZY Regional Vice President Century Motors of S. FL Pompano Beach, FL (954) 785-0369

www.fiada.com

STEVE MARBAIS GEORGE HICKEY Regional Vice President Regional Vice President Marbais Enterprises, Inc. Bond Auto Sales Ocoee, FL Tampa, FL (407) 877-7422 (813) 238-7478

PAUL MATTON Treasurer Park Auto Mall Pinellas Park, FL (727) 639-1112

GOVINDA ROMERO Regional Vice President Autoflex LLC Gainesville, FL (407) 468-9974

June 2014 — Independent Dealer — 31


Manheim Caribbean Subasta De Autos Bo. Candelaria Carretera 865 Km 4.7 Toa Baja, PR 00949 Phone: (787) 261-7300 Sale Day - Thursdays 11:30am

4

General Motors Closed Factory Sales bi-weekly on Monday at 1:00 p.m.

Palm Beach Nights, Mondays, 4:00 p.m.

Toyota & Lexus Sell-A-Thon every other Thursday at 4:00 p.m.

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Total Resource Auction every Thursday 11:00 a.m.

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©2012 Manheim, Inc. All rights reserved. Manheim Buy. Sell. Win. is a trademark of Manheim, Inc. The M logo is a registered trademark of Manheim, Inc.

32 — Independent Dealer — June 2014

www.fiada.com


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