ComplianceCast October 2008

October 2008 — While the current economy is full of obstacles for auto dealers, the greatest challenge is letting people know that now is a great time to buy a car. Read on for strategies to help customers, lenders, and the industry switch from fearful to fearless.

	There Is No Auto Credit Crisis Ed Wallace of BusinessWeek outlines “six truths” that support why he believes that auto sales are down not because of the credit financing crunch but rather because Americans aren’t shopping for cars. BusinessWeek

	Most Important Customers At a time when finding new sales prospects is proving to be more challenging and costly than ever before, turning to your existing customers may be an effective solution to keeping your sales floor from feeling like a ghost town. Lithia Motors Inc. shares its strategies for earning business from repeat customers, including what it would’ve done differently. Ward's Dealer Business

	Selling Lenders on F&I Products The goal of the F&I office is to sell a customer on a product, but in today's reality it's the lender that needs to be sold. Denny Sims lays down a five-step plan for making the dealership's F&I products more appealing to the lender. F&I Management & Technology

ALERT: FTC Grants Six-Month Delay In Red Flags Enforcement Affecting Certain Groups

On October 22, 2008 the FTC announced it would suspend enforcement of the Red Flags Rules from November 1, 2008 until May 1, 2009. Because this rule change affects some Compli customers, we wanted to update you with additional information provided by Michael Benoit of Hudson Cook, LLP. There are exceptions to this rule that may impact your business, so please review the information below carefully and contact your legal counsel and appropriate regulatory agencies governing your business (especially for those businesses that are not auto dealers).

Note: The below provides legal information that should not be construed as legal advice. We recommend you consult counsel if you want assurance that this information, and your interpretation of it, is appropriate to your particular situation.

Auto Dealers

Auto dealers are under the jurisdiction of the Federal Trade Commission. As such, the six month suspension of enforcement applies to dealers. However, dealers should continue the implementation of their programs on their current schedules and not wait until May 1, 2009. This is the right business practice for those who are looking to avoid fines and protect their business from all forms of identity theft. Having your program humming before May 1st will help to further protect you from steep fines once the new deadline passes. It will also be your best defense should you experience any form of ID theft incident in your dealership.

Banks, Credit Unions and Others

All regulatory agencies other than the FTC are observing the original November 1, 2008 mandatory compliance date for the Red Flags Rule. All non-dealer customers should check with their legal counsel and/or federal functional regulator if there are any questions.

Restrictions That May Affect You

The FTC’s suspension does not apply to two significant areas of their enforcement policy. They are:

1. Rules regarding address discrepancies applicable to users of consumer reports (16 CFR 681.1). Auto dealers are subject to this rule, and must be in compliance on November 1, 2008.

2. Rules regarding changes of address applicable to card issuers (16 CFR 681.3). If this is part of your business practices, you should carefully review these rules, and be in compliance with them by November 1, 2008.

Compli and Hudson Cook, LLP are on hand to help you understand how this rule change affects your business. Visit http://www.compli.com/red-flags/ for more information.

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Introducing EORM, Compli's New EH&S Partner

Compli and EORM [Environmental & Occupational Risk Management] have partnered to deliver new content to customers as one more piece to the compliance puzzle. Programs will include employee training, policies, workflow management and expert guidelines to support EH&S compliance efforts.

Dealers using the Compli DCMS will now have access to key EH&S information that can save thousands of dollars per location while giving them a more effective, flexible and scalable program.

The following content programs will be released during Q4 of 2008:

•General Safety a.k.a. Injury Illness Prevention
•Emergency Action Plan
•Ventilation & Indoor Air Quality
•Ergonomics
•Hazard Communication
•Hazardous Energy Control

As the leading provider of strategic high-value environmental, health and safety management and technical consulting services, EORM is aligning its business practices and principles by committing to excellence in environmental performance, and the health and safety of their employees, customers, and communities. Meeting this commitment is a primary management objective and the individual and collective responsibility of all EORM employees. Their objectives are to:

• Meet or exceed applicable environmental, health and safety laws and regulations and other requirements;

• Continually improve their performance-based HSE (Health Safety and Environmental) Management Systems;

• Ensure that their business practices and services are aligned with their HSE (Health Safety and Environmental) policies and goals;

• Minimize the environmental impact of their operations by conserving natural resources, eliminating waste, reusing and recycling materials, and responsibly managing energy use;

• Motivate and prepare all employees to take personal accountability for protecting the environment and creating a safe and healthy workplace; and

• Be a leader in deploying and promoting innovative, cost-effective environmental, health and safety programs and procedures.

To learn more about EORM, visit http://www.eorm.com/.

ComplianceCast October 2008 | Compli.com