May 16, 2023
By Michael G. Charapp
Charapp & Weiss LLP
As we have discussed regularly, regulatory agencies, particularly the FTC, have never been so active. A dealer must be prepared.
Even before administrative charges are brought or a lawsuit is filed, the FTC will issue a civil investigative demand on which a dealer will spend more than six figures in attorneys’ fees and internal costs. The answer to preventing that is a sales and F&I regulatory program.
A checklist to develop one is attached, as is an update to our federal advertising checklist (which is referenced in the Sales and F&I one).