1. By Nick Zulovich, Editor
ATLANTA — With new survey reports
showing independent dealers are fearing a
significant decline in customer traffic, Equi-
fax is offering new tools for members of the
National Independent Automotive Dealer-
ship Association and National Alliance of
Buy-Here, Pay-Here Dealers to create what
company executives are calling a “transpar-
ent environment” for customers with check-
ered credit backgrounds.
BHPH dealers who are NIADA or NABD
members can report their consumer auto
loans and payments to Equifax without
having to pass traditional barriers such as
holding a certain number of accounts. Pre-
viously, operators needed to have at least 500
active accounts to send this information.
“That’s a really big deal because we’re
making it easier for the smaller dealers now,”
said Angelica Jeffreys, vice president and
dealer leader for Equifax. “We’re trying to
encourage transparency in this segment of
the dealer population, giving them the tools
they need to be a better, more-customer
friendly organization.”
Jeffreys explained reporting trade lines
not only improves the data available to deal-
ers for qualifying future potential buyers, but
it also encourages customers to make timely
payments because their credit rating may be
directly impacted by how they perform on
their loan.
In addition, she added dealer reporting
will add trade lines to a consumer’s credit file
to more accurately reflect their handling of
debt, which may grant them even more op-
portunities for competitive terms based on
their credit history.
Jeffreys recollected a dealer survey Equi-
fax recently completed with the assistance of
NABD. She pointed out that 64 percent of
what she called “progressive” BHPH deal-
ers already reported credit activities to bu-
reaus such as Equifax. That group included
operators in 43 out of 50 states.
“That’s a good sign of taking steps to cre-
ate a transparent environment that’s good
for consumers. The consumers will have the
benefit of that reporting,” Jeffreys said.
The Equifax executive went on to em-
phasize how the move to work with dealers
of all sizes who are members of NIADA and
NABD is showing the commitment to this
space by the multi-billion dollar company.
“For a company like Equifax to open
these doors, let’s face it, the independent
market is a little more risky,” Jeffreys said.
By Nick Zulovich, Editor
CARY, N.C. — Buy-here, pay-here deal-
ers might not have any problem purchas-
ing a toy for their children or a gift for their
spouse online. But acquiring inventory —
especially vehicles at the price points where
most operators need to stay in order to gen-
erate the margins they need to survive —
that’s a whole different ballgame.
When BHPH Report reached out to a
wide array of auction executives to gauge
the reasons why this dealer community in
particular remains apprehensive about pur-
chasing a large amount of inventory online,
Keith Crerar offered six factors that sum-
marized the sentiment. Crerar, who is cur-
rently is vice president of dealer sales at AD-
ESA, mentioned:
• The sensory experience
• Trusting the accuracy of the condition
report
• Training the condition report writer to
standardize it and remove subjectivity
• Implementing better science
• Transportation delays
• Lack of high-quality images
“Dealers are used to touching and
smelling a car, sometimes even sitting in
it. And there’s a little bit of value to that,”
Crerar said.
“We hear that as a top concern that they
use that information to judge a car and
when they buy online, they’ll miss the sen-
sory experience,” he continued. “They say
that they can’t really get the same impres-
sion of the car from images online.
“But as our technology is continually
improving, we are able to incorporate more
and more high-resolution images that allow
buyers to zoom in on the vehicle, so that
should be less and less of a concern,” Crerar
went on to say.
Questions about vehicle
condition
For several years in a row now, the
Mike Roberts, who leads the Wholesale Institute for Cox Automotive, explains
how to buy vehicles online during a seminar earlier this year in Raleigh, N.C.
PRSRTSTD
USPOSTAGEPAID
E.GREENVILLE,PA
PermitNo.555
CherokeeAutomotiveGroup|301CascadePointeLane|Cary,NC27513
THE PHOENICIAN RESORT | SCOTTSDALE, ARIZONA
Nov. 16-20, 2015
THE PRE-OWNED CONFERENCE
Used Car Week is proud to partner with the following
industry associations during this year’s event.
800.608.7500
www.usedcarweek.biz
PhotobyJonathanFredin
July/August 2015 | Volume 2 | No. 6A Publication of NABD and SubPrime Auto Finance News
Auctions out to ease online buying apprehension
MEMBERS continued on page 17
AUCTIONS continued on page 3
Equifax removes reporting minimums for NIADA and NABD members
Do you truly treat this as
a collections business?
Why NY dealer
settlement impact
might ripple elsewhere
6
13 18
Beggs joins NIADA Ring
of Honor as dealers
honored at convention
4. 4 BHPH REPORT Vol.2 No.6
BUD
ABRAHAM
Elevating the vital role of the detailer
By telling inspiring
stories of detailing
staff taking a
proactive,
engaged and
proud stake in
their role, the
detail industry
can help push
the detail
narrative forward
— and move
beyond negative
perceptions.
Talk to any dealer and he or she will tell you
that reconditioning (detailing) is vital to their
dealership, yet the role of the detailer is often per-
ceived negatively.
And for the detailer, there is a lot more at stake
than negative stereotypes.
Detailers are exposed to a great many chemi-
cals, which can cause occupational asthma. There
is also a host of other dangers that could come
from mixing the wrong chemicals, and the in-
creased likelihood of slip-and-fall injuries, not to
mention the potential impact on used-car sales
and profits.
Despite all of these risks, detailers play a huge
role in the profitability of the dealerships. Then
why the bad reputation, and why are they and the
department treated so badly?
There are a number of reasons for this situ-
ation — there are no education requirements or
necessary certifications for detailers anywhere in
the United States. Then, there is the problem of
low pay; most detailers are paid by the car or just
above minimum wage.
It is all theory regarding why the detail indus-
try has not advanced in the United States. Never-
theless, the prevailing thought is that most dealers
or detail business owners want to keep the wage
rates low. However, once you start attaching cer-
tifications to any profession, it raises the amount
you have to pay people. Detailers work hard, they
do a dirty and repetitive job, they work late at
night and there are many things that can
go wrong.
They deserve to be paid fairly and treated as an
integral part of the dealership.
Training means retention
Turnover is a constant problem in detailing,
with rates cited anywhere between 50 and 400 per-
cent by dealers and detail business owners. That
means dealerships could be replacing their entire
workforce between once every two years and four
times per year.
Training programs are an underutilized way
to help tackle this problem. Not only does regular,
in-depth training provide the opportunity to raise
pay, but it also shows workers that the dealership
cares about them, enhances skills and job perfor-
mance, and helps with turnover.
The key, of course, is, you must have people
who are capable of being trained. You cannot im-
prove the detail employee by continuing to hire
the same type of people repeatedly. You will just
keep getting what you always have.
With the people we have trained, we have seen
that the programs that have led to higher pay also
lead to better retention. One of our customers had
an incentive program so that detail staff would
make more money as they advanced through the
stages of training.
After two years, most of these employees are
still there. They do not use training to weed people
out, but people weeded themselves out.
The budget often has the final say in training
decisions. Many dealers do not see the value in
training when they look at it on paper. They see an
upfront cost, the potential of having to pay more
for certified and trained detailers, and the loss of
man-hours that are spent training as negative im-
pacts on the bottom line.
Some dealers do not want to train people be-
cause they are afraid they will go somewhere else,
but on the other side, what happens if you do not
train them and they stay? Training will work if you
hire the right people; you will get a positive return
on your investment.
Promoting higher worker value
Our approach to training is simple — get
knowledge into the detailer’s head — knowledge
about chemicals, technology and the supplies
available to detail vehicles properly. Additional-
ly, knowledge about the vehicles: paint finishes,
wheels, leather, carpets, glass, etc. Most detailers
we find have no real knowledge of the vehicle and
are using techniques for detailing from the ‘50s.
The hands-on training breaks the detail jobs
into these categories:
1. Engine clean
2. Wheels
3. Body wash
4. Tar removal
5. Trunk clean
6. Complete interior clean and shampoo
7. Exterior buff, polish and wax
8. Final detail
For each of these jobs there is a step-by-step
process so every detailer does the same thing, the
same way. This gives management control over the
entire detail process, instead of every detailer do-
ing it “their way.”
Professional organizations, such as the Interna-
tional Detailing Association, have training that re-
sults in a certification, but it is a lengthy program
that involves several on-line tests, and then hands-
on training at an IDA recognized location. This is
probably too long and too expensive for dealers.
On-site training is best for a dealership —
training the entire staff at your location, using
your tools and chemicals. You do not have to buy
into a complicated training program to find in-
depth, high-quality training for your detail work-
ers. There are several good trainers who will come
to your dealership.
Of course, a dealer can go to their chemical
supplier and ask for hands-on product and pro-
cedure training, but there is a question about the
caliber of training they are going to receive. Most
chemical companies only train to understand and
use their chemicals, so your detailers are not real-
ly trained at all.
Rather, find a training program that moves
beyond how to hold a buffer and delves into the
chemistry behind cleaning.
One way to identify a high-quality training
program is to ask how often the staff should be
trained. That is a good question to define what the
supplier really thinks training is. It is like going to
the gym. If you go once or twice a year it is not go-
ing to make a difference. Training is the same way.
If it is repetitive and constant, you are definitely
going to get more buy-in from the staff.
There is no magic training program that is go-
ing to transform your detailers into technicians if
they are the wrong individuals, and the training
is just a one-time thing. It is a continuous process
with periodic refresher courses.
The impact of recognition
and praise
There is a famous story about President John F.
Kennedy’s encounter with a janitor who was clean-
ing a bathroom at NASA. Kennedy asked the man
what he was doing, to which the custodian replied,
“Mr. President, I’m helping to put a man on
the moon.”
That is the kind of pride that exemplifies the
true role of a person’s work. By telling inspiring
stories of detailing staff taking a proactive, en-
gaged and proud stake in their role, the detail in-
dustry can help push the detail narrative forward
— and move beyond negative perceptions.
Detailers have the capacity to improve the
meaning and identity of their work by being pro-
active, engaging with others and seeing their val-
ue in the larger context of the organization. But it
is up to the dealer to create this atmosphere. If the
detailers are not engaged, nothing will change.
I have interviewed groups of detailers in deal-
erships that fell into two groups: one group did not
like detailing and did not value their skills or role
as a detailer. The second, happier group took great
pride in their work.
I noted the happier detailers understood the
value of their work at the dealership and altered
the relational nature of their job to form bonds
with everyone in the dealership. These detailers
enjoyed the work and felt they were highly skilled.
They engaged in tasks that made the jobs and lives
of sales people easier.
How do dealers promote this proactive,
heightened sense of value in their detail staff and
their entire dealership? Training helps. But praise
and recognition are critical. The detailers have to
see themselves as part of the whole, and the entire
dealership must reflect this respect towards the
detail staff.
Taking the time to notice when the job is be-
ing done well will pay huge dividends in lifting de-
tail employee morale and keeping them around
longer.
Invite in a training company to provide train-
ing for the detail staff. Then try something as sim-
ple as giving detail staff a certificate and a pat on
the back, and telling them that training was im-
portant because what they do has a major impact
on the dealership. Do this and do it well, and you
will see less tardiness, less sleeping on the job and
an overall upgrade in the work.
Finally, a pat on the back by the dealer prin-
cipal cannot be underestimated. When you are
talking to a group of detail employees, you do see
them stand a little straighter when you tell them
nobody else in the dealership has a more direct ef-
fect on the profitability of the dealership than they
do. Unfortunately, it is a message that dealers do
not deliver enough.
If you are interested in learning more about
training, contact me at buda@detailplus.com.
5. July/August2015 bhphreport.com 5
How
dealers
avoid
flood-damaged
vehicles
Josh Hyatt, Staff Writer
CARY, N.C. — There’s quite a bit of hub-
bub being made in the consumer-facing me-
dia following the recent flooding in Texas
and the vehicles that suffered water damage.
The National Insurance Crime Bureau,
based on estimates from Copart, recently
reported that the fallout from the flooding
affected between 7,000 and 10,000 insured
vehicles in the area. While the majority of
media is focused on warning consumers,
this feature will hone in on protecting auc-
tions and dealers alike.
There is a good chance that there will
be folks who try to trade in a flood-dam-
aged vehicle or that many of these cars may
end up at the auction. But through Auto Re-
marketing’s recent conversations with deal-
ers around the country, it seems there are
a variety of ways for the industry to handle
this challenge.
Dealers we’ve reached out to, from both
coasts and even in the heart of our automo-
tive industry in Michigan, have said they
haven’t seen any impact in trade-ins or in
the lanes from the recent Texas floods.
One such dealer, who is intimate-
ly familiar with flood-damaged vehicles, is
Frank Fuzy, owner of Century Motors of
South Florida in Pompano Beach, Fla.
Positioned near the coast of the Sun-
shine State and less than an hour’s drive
from Miami, Fuzy — with 31 years of au-
tomotive sales in both retail and wholesale
settings — is no stranger to identifying the
negative effects of water on vehicles.
“It would be pretty obvious if you had
any more than a foot of water in a car,” Fuzy
said. “I’m sure when the floods hit, it was
probably that brown Texas color so I’m sure
it would be excessively stained. I’ve seen
some flood cars down when the hurricanes
hit the Keys, and I’ve seen where I’ll have
shells in the engine blocks in a Toyota or
something. You can see the rust line and the
water line, and fair enough, you can check
under the seats, and they’re all rusty, too.”
One pro tip that Fuzy provides is simple:
check the seat tracks to see if they will move.
“Those seat tracks will freeze up pret-
ty quick if they’ve been wet,” Fuzy said. “So
that’s usually a good tell-tale.”
Fuzy, although not worried about the
potential threat, knows better than to not
expect the unexpected, even though he
hasn’t seen any sign of flood-damaged ve-
hicles recently.
Fuzy said, “It’s probably that it’s not a
real issue for us now, but it’s definitely good
to watch out for.”
For any vehicle that has been mostly or
completely submerged, Fuzy says it’ll be
pretty obvious that you need to avoid it.
“A fully submerged car, if it was
ever wet, I could smell it probably without
even opening the door,” Fuzy said. “Those
should be pretty easy to detect. The second
item is if it’s submerged up to the seat lines
— usually, if the power seats don’t work,
that should be a red flag. There’s no reason
the power seats wouldn’t work in the car
unless it went under water and the modules
got wet.”
Although a vehicle may have some flood
damage, the extent of the damages may not
mean the vehicle is a complete wash, so
to speak.
“I have had Corvettes come in, they sit
low, and I have seen wet seat tracks,” Fuzy
said. “But the extent of the water in the car
was about an inch or two, not like a foot un-
derwater, so all the computer stuff works.
It just depends on how you evaluate a
flood car.”
On the West Coast at Capistrano Volk-
swagen in San Juan Capistrano, Calif., you’ll
find Harry Haber, the dealership’s used-
car manager.
Haber, whom we spoke with toward the
beginning of June, is approaching the sit-
uation with a conservative mindset, even
though he hasn’t personally seen any flood-
damaged vehicles in about a year.
“Anything from the Texas area, present-
ly, if I see a registration or a prior history
that a car was in the state of Texas I’ve been
kind of shying away from those cars unless
they’re from a financial consignment lane,”
Haber said.
“Today I was previewing some cars and
they had Texas registrations on them here
in the state of California,” Haber continued.
“They’re at the auctions. I marked ‘no inter-
est’ on them.”
Blaine Marston, the general manager
of the CARite location in Monroe, Mich.,
echoed a similar message.
“We have not seen any flood vehicles,”
Marston said. “If discovered, we would not
retail a flood-damaged vehicle.”
To recap, here are just a few spots rec-
ommended to check for flood damage:
■ Seat tracks: Do they move? Are they
rusty? Check the bolts on the rails and look
under any caps — if the bolts are rusty, the
vehicle may have previously been involved
in a flood. If the vehicle has power seats, do
they function?
■ Engine bay and exterior: Are there
water lines anywhere in the engine com-
partment or on the outside body/inside the
fender wells? Rust lines? Unusual debris?
■ Interior smell: Does the vehicle have
a musty odor? Is any of the interior up-
holstery discolored or look unusually new
or replaced?
“Those seat tracks
will freeze up pretty
quick if they’ve been
wet. So that’s usually
a good tell-tale.”
Frank Fuzy,
Century Motors
of South Florida
6. 6 BHPH REPORT Vol.2 No.6
OVERLAND PARK, Kan. — Before we
get to the content concerning the title of this
article, I want to ask you two questions: How
much do you value the collectors in your
business? And, what kind of tools do you
provide to help them succeed?
I have the honor of working with buy-here,
pay-here and lease-here, pay-here dealers on
a daily basis and get to dive into all aspects of
their operations. Some dealers are doing a great
job running their business and simply want
a second set of eyes to review their processes
and procedures and make minor tweaks. Other
dealers are really struggling and on the verge of
losing their business.
Why do I tell you this? Because there is one
common theme that stands out amongst the
successful dealers, and that theme is collections.
The successful dealers have accepted and
understand that BHPH and LHPH is a collec-
tions business. They spend a great deal of time,
effort and money making sure they have the
best collection staff, training and procedures
in place.
At this point, you may be saying to yourself,
“Yeah, yeah. I’ve heard this all before. I under-
stand it’s a collection business. Tell me some-
thing useful.”
Every dealer I work with tells me they un-
derstand the importance of collections, but as I
tell my 13-year-old daughter every day, actions
speak louder than words.
I still see dealers spending a great amount
of time hiring, recruiting and training the sales
staff. There are daily or weekly sales meetings
to discuss lost deals, lot traffic, follow-up activi-
ties and more. Sales pay plans are constantly ad-
justed to encourage more appointments, more
down payment and more sales.
Don’t get me wrong; I’m a huge fan of
sales training and do a great deal of it for my
clients. But while all this training is going on
with the sales people, the collectors are going
back to their office with very little training or
encouragement. Their interaction with your
customers is the single biggest determining
factor to the success of your dealership.
Read that last sentence again. Am I the only
one that thinks this is crazy? I continuous-
ly see salespeople that make a very nice income
and meet sales managers or owners that do a
great job managing the sales activities. Rare-
ly do I meet a collector or a really good collec-
tions manager that is the highest paid employee
in the dealership.
I think it’s pretty easy to understand why
this happens. I started my automotive career
in the new-car business as a salesperson and
moved up through F&I and eventually became
GM of a Chevy store.
Where did I spend most of my time? It was
spent in the variable operations because that
was where I was most comfortable. I knew the
service department was extremely important
to the success of the store and fully support-
ed them. However, I didn’t do a very good job
of learning that part of the business or develop-
ing a plan to make sure I was hiring the best tal-
ent possible and giving them the training they
needed.
Worse yet, I did a very poor job of inspect-
ing what I expected and holding my team
accountable.
As BHPH/LHPH dealers, a lot of us are
comfortable with the sales side of things, but we
have very little experience with collections. Nat-
urally, we spend the majority of our time think-
ing about advertising to drive traffic and hold-
ing our sales staff accountable to tracking and
converting that traffic.
If you want to take your business to the next
level, I absolutely believe that for every hour
you spend with your sales staff, you should
spend three hours with your collections staff.
I also feel very strongly that a great collector
should be one of the highest earners in your
dealership. I like to see a collector pay plan
that consists of 65-percent base salary and
35-percent bonus and commission.
How important is repeat and referral busi-
ness to your success? Your collections staff is
the number one element that will determine
whether your hard–earned customers come
back to buy their next vehicle from you and
whether they will refer friends and family to
you. The sales department sells the first car; the
collections department sells the repeat business.
This is why BHPH and LHPH is truly a collec-
tions business.
We know we are selling vehicles to custom-
ers who have not paid their bills very well in
the past. We know they are going to run into
life emergencies that are going to prevent them
from paying us on time. And, we know it is our
collectors who are going to have to help the cus-
tomer solve these problems. This is why BHPH
and LHPH is truly a collections business.
Have we done a great job recruiting and hir-
ing people with the right skills to be a great col-
lector? Once hired, have we given them the
proper amount of initial and ongoing training
they need to be successful?
Do we spend the appropriate amount of
time with the collectors each day inspecting
what we expect and giving immediate feedback?
Are our pay plans structured to encourage and
reward outstanding performance?
If you answered no to any of those ques-
tions, you have an area in your business where
you can make an immediate and substantial
difference.
Dustin Kerr is an executive conference mod-
erator for 20 groups NCM Associates, spending
more than 10 years managing BHPH dealerships
in Oklahoma. Kerr can be reached at (913) 827-
6677 or dkerr@ncm20.com.
Do you truly treat this as a collections business?
The successful
dealers have
accepted and
understand that
BHPH and LHPH
is a collections
business.
DUSTIN
KERR
8. 8 BHPH REPORT Vol.2 No.6
10 questions BHPH dealers should ask in light of CFPB’s latest rule
FORT WORTH, Texas — The Consum-
er Financial Protection Bureau issuance of the
larger participant rule early this summer came
as little surprise to much of the industry. But
SecureClose chief legal officer Steve Levine
said many buy-here, pay-here dealers and oth-
er finance companies may not realize how far
the rule will reach — likely impacting more
than just large participants.
Levine reiterated the official language ex-
tends the CFPB’s supervision to any nonbank
auto finance company that makes, acquires
or refinances 10,000 or more loans or leases
per year.
“But that’s only the technical threshold.
In reality, trickle-down pressure from cap-
ital sources, floor plan providers and cred-
it reporting agencies — all of whom are ac-
countable for the actions of dealers they do
business with — will place even the smallest
dealers and lenders under the microscope,”
Levine said.
“Not to mention plaintiff’s attorneys, who
seek out new cases based on the CFPB’s fo-
cus areas, as well as local and state regulators
who regularly pursue businesses below the
10,000-loan-or-lease threshold,” he continued.
Levine asserted that every BHPH deal-
er and finance company should assess wheth-
er they provide consumers with truly un-
derstandable explanations as to what they
are agreeing.
“Car buyers are often confused about the
terms of their deal, and this misunderstand-
ing — combined with inadequate disclosures
or proof of disclosures — leads to unnecessary
conflict and often legal action,” he said.
“We see time and time again that the best-
informed customers end up being the best-
performing customers,” Levine added.
Levine said SecureClose offers a solution
that fully satisfies these disclosure and docu-
mentation needs from the perspective of reg-
ulators, lawyers and buyers. SecureClose tech-
nology automates the closing process by using
a computerized avatar to verbally walk each
customer through his or her deal terms, while
sharing legally compliant, easy-to-understand
commentary along the way.
“It’s like having a lawyer close every deal
— and having a cloud-based video record to
prove it,” Levine said.
Levine went on to say traditional scripts
or videotapes of closings — while some-
times helpful — are not nearly enough in to-
day’s environment, due to the high price of
human error.
“Dealers must ensure that customers re-
ceive the right message, every time — and that
closings are not compromised because an em-
ployee is tired, untrained or wants to close the
deal at any cost,” Levine said.
“I’ve written countless closing scripts,
and with SecureClose, for the first time I’m
truly confident that my legal work is actu-
ally provided correctly to the consumer,”
he continued.
Levine recommended that all dealers and
finance companies respond to the CFPB’s latest
rule by asking themselves 10 questions. He cat-
egorized them by the bureau’s areas of concern:
Fairly marketing and disclosing
financing terms
1 Do our advertising and marketing ma-
terials accurately disclose the true
deal terms?
2 Do we provide simple checklists that ex-
plain the auto financing terms in a custom-
er-friendly way?
Providing accurate information to
credit bureaus
3 Do we have a documented process that
matches the complexity of our business?
4 Do we provide credit reporting train-
ing and testing at least twice per
year to employees tasked with this func-
tion, and do we document their personnel
files accordingly?
5 Do we conduct adequate investigations of
every single dispute, and can we demon-
strate the process?
Treating consumers fairly when
collecting debts
6 Do our customers know all the payment
options available to them?
7 Are our invoices, collection letters and
call strategies synchronized so custom-
ers receive a consistent message instead of a
confusing one?
8 Are we taking advantage of online pay-
ments, Interactive Voice Response
(IVR) and text messaging, all of which lever-
age technology and avoid confrontation with
the customer?
Lending fairly
9 Do we practice menu selling so no cus-
tomer can claim different treatment?
10 Do we provide written explana-
tions of each add-on product’s
key benefits?
Levine and other SecureClose execu-
tives — including chief executive officer Allen
Dobbins, formerly of AutoStar Solutions, and
founder and chief vision officer Ace Christian,
owner of Rock Solid Auto in Mesa, Ariz. — will
be on hand to discuss the full impact of the CF-
PB’s announcement at the Texas Independent
Automobile Dealers Association annual con-
ference in San Antonio on Aug. 9-12, and In-
novate: The Independent Dealer Industry
Conference in Fort Worth, Texas, on Sept.
20-23.
MIAMI — GPS tracking solutions pro-
vider Skypatrol released what it’s calling a
time-saving solution for batch communica-
tions to customers in your related finance
company portfolio who are behind on mak-
ing their installment payments.
Skypatrol highlighted its AutoBatch for
DMS can give buy-here, pay-here dealers
and vehicle finance companies the capabili-
ty to automate DMS-driven “machine to ma-
chine” (M2M) commands to contract hold-
ers in default. Now, operators can leverage
the power of their existing DMS to output a
list of defaulting customers and the type of
action that is required.
This list is automatically emailed M2M,
and Skypatrol’s secure servers communicate
with the borrower’s GPS turning on a piezo,
sending location information or deactivating
the vehicle if parked.
Officials explained this process is
completed fully independent of any system
integration or application program interface
(API) exchange, making it easy for Skypatrol
customers to implement the solution across
all popular DMS platforms without special-
ized technical support.
Each time commands are distributed,
a detailed report is sent confirming the ac-
tion took place. If for some reason the vehi-
cle can’t be reached, the system automatical-
ly retries to establish contact — which is re-
ported as well.
Depending on how much of your port-
folio is in some level of default, Skypatrol in-
sisted it’s vital that BHPH dealers and finance
companies have an efficient methodology for
asset protection.
Skypatrol’s product and service solution
combines proprietary GPS devices with in-
novative software systems that can help boost
portfolio performance, increase operational
efficiencies and reduce risk in the vehicle
finance industry.
The AutoBatch for DMS system can com-
bine with Skypatrol’s other finance industry
products for a complete end-to-end solution.
Its one-click Repo Mode Tool can gives time-
limited secure smartphone access to recov-
ery teams of a vehicle’s current location.
“Auto Batch for DMS will save lenders
and dealers the manual and labor intensive
task of individually creating actions one at a
time when no integration is possible,” Skypa-
trol chief operating officer Larry Jones said.
“There are some DMS systems that don’t
allow integration due to the lack of an API,
there is a deficient API or it is a legacy sys-
tem,” Jones continued. “Either way, find-
ing a way to work outside of an API is just
what our customers need to remain efficient
and competitive.”
Furthermore, Jones mentioned
Skypatrol’s Data Verification Tool can qualify
applicants and help locate them if they skip.
Its Virtual Collector module can send auto-
mated email and text reminders, increasing
cash flow and reducing defaults.
“I am a very strong proponent of prod-
ucts that automate communications and ac-
tions around the default process,” said Jim
Rhoads, a consultant to the BHPH industry.
“By removing the potential for human
error, reaction to delinquency is timely and
consistent,” Rhoads continued. “It also de-
personalizes part of the process, allowing
collectors to effectively blame ‘the system’ for
early and persistent reminders.
“Automated communication also reduces
the level of frustration that builds in collec-
tors when they are unable to reach the debt-
or/customer and it frees collectors up to do
the more important work of solving prob-
lems,” Rhoads went on to say.
Skypatrol enhances DMS integration to automate messages to defaulted contract holders
9. July/August2015 bhphreport.com 9
Single Interest Insurance, Inc.
18489 N. US Hwy 41, #267, Lutz, FL 33548
813-361-3525
email:ecsind@hotmail.com www.singleinterestins.com
PROTECT YOUR AUTO LOANS
VSI/CPI
Customer drops insurance
and wrecks – We write
you a check.
B-H-P-H Consulting & Training
GPS TRACKERS
Skip Protection
If the customer disconnects the
GPS Tracker – We will fnd your Skip.
Skip Service – We will fnd your Skips.
Q: What kept you motivated after you hit an eight-fgure portfolio?
I don’t think there is a soul out there who doesn’t want to make more money this year and more the next year afer that. Everybody wants to make more and more and more.
Given the fact that we have 70, 80, 100 people working for us over the years, now I think it’s about 120, the bottom line is everybody wants to make more money. So in order to do
that, you have to sell more cars. Consequently, based on the fact that the employees wanted more, I wanted more. How do you get more? You’ve got to work a little harder. You’ve
got to push a few extra hours. And more advertising. Tat was always my key, advertising. Tat’s what drives me to make more money, not only for me, but for every employee.
Ed says ...
Again, I have a passion for the car business. I don’t know what it is. I guess I equate it to the hunter who goes out and hunts, or the fsherman who goes out and fshes and get
some kind of exhilaration from catching the big fsh or getting the big game. My exhilaration came from selling a car. Everybody who is in the car business and gets questions from
someone outside the car business, they ask, what’s your favorite car? I always say it’s the one I just sold.
But I’m also goal oriented. At Credit Acceptance for example, we set goals in 2000 and they were 14-year goals. And at 2014 we hit the goals so we just reset our goals for 2025.
Why that number? Our CEO is going to be 60 years old at that point. At CARite, it was the same thing. We set goals at the start. For me, that’s the excitement. It’s making those
goals and not just making money. Te money comes along with it when you make your goals.
Don says ...
To me, I’m a goal-oriented person. I’m a competitive person. My thought was
if one month we sold 100 units, the next month I wanted to sell 101 or 110. We
wanted to do a little bit more each time. So whatever we had to do to tweak our
business model to improve our fundamentals, that’s what we did. We always tried
to improve. I was my own competition, regardless of what the others did. Te only
competition I knew of was how to keep moving things forward.
John says ...
I think what kept me going was it is fun. I was having a great time. One of the things I learned along the way was about my own shortcomings. When we thought about tak-
ing the company public, I found out exactly what it meant to grow a business at 20 percent a year and applaud anybody who can do a lot better than that. But I tell you, I got to the
point where I knew I wasn’t the guy who could do that. But the thing that kept motivating me was I was having a great time. I was just having a lot of fun.
Julian says ...
Ask the
Hall of Famers
Ed
Bass
“When you get into the Hall of Fame, it’s not about
having a good year or two good years. It’s about
having a lifetime of good work and to make a
difference in the lives of other people.”
Ken Shilson, NABD Founder
Don
Foss
John
Linnehan
Julian
Codding
13. July/August2015 bhphreport.com 13
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Betcha Don’t Have
These Digits
Beggs joins NIADA Ring of Honor as dealers honored at convention
LAS VEGAS — Ricky Beggs, former-
ly the senior vice president at Black Book,
was recently named to the National Inde-
pendent Automobile Dealers Association’s
Ring of Honor during the 69th annual NIA-
DA Convention and Expo at Caesars Palace in
Las Vegas.
NIADA awards this honor each year to an
executive demonstrating outstanding perfor-
mance and leadership, while also helping the
auto industry grow.
Beggs retired in April after 34 years with
Black Book. One of the most respected leaders
of the remarketing business, Beggs has been a
key voice and provider of insight to the indus-
try. He is the fourth person from Black Book
to earn Ring of Honor distinction, which has
now been awarded to 24 people.
“I am truly honored to have been able
to have some influence on Black Book and
the automotive industry and honored to be
amongst this group of past recipients that
have had a major impact on the way used cars
are sold,” said Beggs. “I would not be receiving
this special award without the efforts of all of
the Black Book associates and especially the
solid work by the entire editorial team.”
More NIADA awards
Elsewhere at NIADA, the association
wrapped up its annual NIADA Conven-
tion & Expo by recognizing many in the
industry for their individual contributions to
the auto sector.
Darla Booher, the president of Deal De-
pot in Greer, S.C., was named the 2015 Na-
tional Quality Dealer of the Year during
the event, chosen from the 20 State Quality
Dealers nominated.
Selected by a panel of judges from North-
wood University based on factors such as
contributions to the industry and communi-
ty involvement, Booher becomes the second
woman to win the award since 2002 recipient
Wanda Lewark.
“Over the years, Darla Booher has earned
an exceptional reputation not only with her
customers and staff, but throughout her com-
munity and within our industry,” said Steve
Jordan, NIADA executive vice president. “Giv-
ing back to her community has always been a
team effort for her and her staff.”
Other professionals honored by NIADA at
the event include:
■ NIADA Association Executive of the
Year: Todd O’Connell, Colorado IADA.
■ Crystal Eagle Award winners: Kimberly
New, Style Financial Acceptance Co.; Dennis
Pope, People’s Financial; Glen Reeves, Reeves
Insurance Agency; Julie Colgate, Indepen-
dent Dealers Advantage; Guy Padgett, Sterling
Credit Corporation; Roy Daniel, ALS Deal-
er Funding; and J. Wayne Meagher of M D
Auto Sales.
■ Honorary Crystal Eagle Award winner:
Frank Fuzy, owner of Century Motors of South
Florida, who was also named as the associa-
tion’s president during the event.
According to the NIADA, O’Connell
earned the award by putting his previously
struggling organization on solid financial foot-
ing, creating an association charity that raised
more than $100,000 in the first year, starting a
dealer defense fund to protect against frivolous
lawsuits, adding an association Ambassador
group to promote CIADA information, and
establishing relationships with state officials.
Five scholarship winners
The NIADA Foundation, each year, spon-
sors a student in each of the association’s four
regions with a $3,500 scholarship to the college
or university of his or her choice. The foun-
dation and Cox Automotive also award one
$10,000 national scholarship once a year for
an exceptional student to help them attend or
continue his or her education at Northwood
University in Midland, Mich. in an automo-
tive-related field.
Here are this year’s five scholarship
winners:
■NIADA/CoxAutomotiveNationalSchol-
arship: Alesandra D’Agostino, who just com-
pleted her first year at Northwood University.
■RegionI:EmmaHammerofIndianapolis.
■ Region II: Philip Hetzler ofMatthews,
N.C.
■ Region III: Cash Forster of Washington,
Okla.
■ Region IV: Maxence Weyrich of
Boonville, Calif.
All of the students’ entries were judged by
Northwood University.
In related news, ADESA, AFC and IAA
helped raised $27,500 for the NIADA Foun-
dation on recently. Andy Gabler, of Lakeside
Auto Sales in Erie, Pa., won a bidding war for
a Mercedes C250W during the NIADA Con-
vention. The three auction companies donated
the vehicle where all proceeds of its sale will be
used to help the NIADA Foundation.
Over the past three years, ADESA/AFC/
IAA-sponsored auctions at the NIADA Con-
vention have raised a total of $69,700 for the
NIADA Foundation.
Ricky Beggs with NIADA’s Steve Jordan.
14. 14 BHPH REPORT
LAS VEGAS — Your Swiss Army Knife didn’t
allow for a lot of torque on tight screws, and the
scissors didn’t cut very well, but the idea was
awesome.
What is the Swiss Army Knife strategy?
While many of your competitors practice linear
thinking and how a tool serves only one purpose,
you can be an independent thinker and focus on
how to use your tools, ideas and strategies for
multiple advantages to your business.
In case you didn’t have one, a Swiss Army
Knife was an all-purpose tool that consisted of a
knife, scissors, screwdrivers and more that could
fit in one little boy’s pocket.
This is how I teach dealers to think about
their marketing and business strategies. For
example:
You can use a Google Pay-Per-Click ad to
send Web visitors to a page on your website
where they are encouraged to fill out a form.
After filling out the form, your new lead is re-
directed to a webpage where they watch a video
of you explaining the “five things to know when
buying a new car.”
At the end of the video you encourage people
to share your video on Facebook with their
friends so they too can be informed.
All of this can take place as part of the lead
generation and car–buying process. But instead
of only attempting to sell a vehicle, you generate
a lead in case they aren’t ready to buy at that very
moment.
Because they filled out a form, they get an
automated follow-up from you. The lead was
directed to your webpage where your YouTube
video is embedded. That video earns another
“view,” which is good for SEO. This YouTube
video contains keywords and tags about car
buying and financing, which is good for SEO for
the video itself (videos are indexed by Google
too). The video has a backlink that points to your
website, which is also good for SEO for your
website.
Videos help to build trust so that a customer
who sees you in video is more likely to agree
to come into your dealership after they have
already seen your smiling face and heard your
voice.
All of this from one ad that led to one
visitor, that generated a lead, helped with SEO,
boosted customer trust and boosted possible
shares with other people in the community.
One idea; multiple benefits.
Here is a specific example of one our
feedback and review system clients using the
Swiss Army knife strategy — some of it is built
into the system, but a part of it is the dealer
deciding to use one tool for multiple benefits:
1 Fix systemic problems that are revealed by
customers.
2 Print your positive feedback from
yesterday, and read it to your team to start
the next day. Inspire employees with positive
reinforcement.
3 Avoid negative reviews that hurt all of
your marketing. When using an effective
feedback system, unhappy customers that vent
to you through your internal feedback system
don’t typically take their negative comments
public.
4 Boost positive reviews to attract more
customers. Some feedback systems like
ours redirect happy customers to a webpage
with direct links to your Google, Facebook and
other review directories. They are encouraged
to write a review, and it is easier.
5 Positive reviews help to improve search
engine rankings.
6 Build trust with customers, and make sure
your first impression is good. This can lead
to increased sales as well as positive reviews
and testimonials on your website.
7 Demonstrate to customers that you care
simply by asking for feedback.
8 Collect customer emails.
9 Demonstrate to the Consumer Financial
Protection Bureau that you are making
every effort to be compliant by using a system
to collect customer feedback. Could this protect
you? Check with your legal department.
By using one feedback tool you can improve
service, boost marketing, increase trust,
improve first impressions, inspire employees
and more.
What are you doing with your tools and
strategies to get the most out of our every dollar
spent?
Kenny Atcheson is the president of Dealer
Profit Pros. He teaches workshops, speaks at 20
groups and his company offers several done-for-
you dealer marketing and advertising programs,
including a newsletter program, a feedback &
review system, pay-per-click management, and
private consulting. His website can be found at
www.DealerProfitPros.com.
Practice independent thinking with the Swiss Army knife strategy
While many of
your competitors
practice linear
thinking and
how a tool serves
only one purpose,
you can be an
independent
thinker and focus
on how to use
your tools, ideas
and strategies
for multiple
advantages to
your business.
KENNY
ATCHESON
15. July/August2015 bhphreport.com 15
3 steps to solidify customer complaint response strategy
CRYSTAL LAKE, Ill. — Especially in
these times of intensive regulator oversite,
Automotive Compliance Consultants pres-
ident Terry Dortch insisted that how your
buy-here, pay-here dealership responds
to customer complaints often determines
whether the store’s good name gets blem-
ished or a lawsuit results.
Viewed proactively, Dortch explained
complaints can help BHPH dealers iden-
tify process and personnel weaknesses to
be corrected.
Dortch acknowledged that every deal-
er knows about customer complaints. But
if operators are not hearing them personal-
ly, he mentioned that perhaps a visit to re-
view websites like Consumer Affairs will
be enlightening.
And the Consumer Financial Protec-
tion Bureau has its complaint database, too.
Consumer complaints possibly made about
your BHPH dealership or related finance
company to the CFPB now are available for
anyone to see.
For the first time beginning this past
June, the CFPB turned on its enhanced
public-facing consumer complaint data-
base, pushing more than 7,700 consumer
accounts of problems they are facing with
financial companies concerning auto loans,
mortgages, bank accounts, credit cards,
debt collection and more.
“The bureau’s work improves as we hear
directly from consumers,” CFPB director
Richard Cordray said. “Every complaint
tells us what people are facing in the fi-
nancial marketplace. Publishing these con-
sumer stories today is a historic milestone
that we believe will lead to better outcomes
for everyone.”
Unlike the CFPB’s database, Automo-
tive Compliance Consultants has found
that most review sites contain a number
of positive reviews, but there are a share
of negative ones about various dealerships,
as well.
Dortch wondered how many complaint
reviews might have never reached social
media had dealers responded to customer
concerns more appropriately, expediently
and kindly.
The firm emphasized that proper re-
sponse to customer complaints is part of
an effective compliance management sys-
tem (CMS). This system describes correct
processes for complaint follow-up and oth-
er best practices for ensuring BHPH deal-
ership compliance with prevailing laws reg-
ulating the business.
“A dealer can have put into place the
right practices to ensure the business oper-
ates according to these various laws, but if
no set policy and responding practices are
put in place for handling customer com-
plaints, the CMS is broken,” Dortch said.
Automotive Compliance Consultants
specializes in dealership and auto finance
compliance, providing in-dealership con-
sultations and analysis, compliance audits
and training, and offers solutions for all
compliance needs.
When establishing a complaint re-
sponse system, the firm explained a dealer-
ship should consider:
■ The types of complaints received, and
how to categorize them. Those from a reg-
ulatory agency, and complaints regard-
ing Equal Credit Opportunity Act claims
should be placed in their own category.
■ How complaints are to be received and
by which individual or individuals within
the dealership.
■ How complaints will be documented,
how information will be gathered about the
complaint, information about the individu-
al making the claim, and each contact with
the customer.
“Respond promptly and appropriately,
whether in your estimation a complaint has
merit or not, as certainly someone believes
you violated their rights and certainly their
emotions,” Dortch said.
“Ignore complaints or respond in a way
that dismisses or demeans the customer
and you’ll likely germinate a potential law-
suit,” he continued.
After receiving, logging and respond-
ing to complaints, Automotive Compliance
Consultants recommended that BHPH op-
erators use them to improve the business,
as they likely point to:
■ Weaknesses in sales and
finance processes
■ Employees that may be exposing the
dealership to risk
■ Needed improvements in customer
handling
■ Broken compliance practices
■ Need for remedial employee
compliance training
The Automotive Compliance Consul-
tants staff has extensive experience in the
retail automotive industry and focuses ex-
clusively on dealership compliance issues.
For more information, contact Dortch
at terry_dortch@compliantnow.com or visit
www.compliantnow.com.
“Every complaint tells us
what people are facing in
the financial marketplace.
Publishing these consumer
stories today is a historic
milestone that we believe
will lead to better outcomes
for everyone.”
Richard Cordray, CFPB
16. 16 BHPH REPORT Vol.2 No.6
CFPB finds 26 million consumers are ‘credit invisible’
WASHINGTON, D.C. — The Consum-
er Financial Protection Bureau published
a report in May finding that 26 million
Americans are what the agency is calling,
“credit invisible.”
The bureau explained this figure indi-
cates that one in every 10 adults do not have
any credit history with a nationwide con-
sumer reporting agency. Officials noted the
report also found that Black consumers, His-
panic consumers and consumers in low-in-
come neighborhoods are more likely to have
no credit history with a nationwide consum-
er reporting agency or not enough current
credit history to produce a credit score.
“Today’s report sheds light on the mil-
lions of Americans who are credit invisible,”
CFPB director Richard Cordray said. “A lim-
ited credit history can create real barriers for
consumers looking to access the credit that
is often so essential to meaningful opportu-
nity — to get an education, start a business,
or buy a house.
“Further, some of the most economically
vulnerable consumers are more likely to be
credit invisible,” Cordray continued.
The CFPB contends credit reports and
the three-digit credit scores that are based
on those reports play an increasingly impor-
tant role in the lives of American consumers.
Most decisions to grant credit and set inter-
est rates for loans are made based on infor-
mation contained in credit reports.
As a result, those consumers who have
a limited or nonexistent credit history face
greater hurdles in getting credit.
The agency acknowledged consumers’
credit histories reflect how they have repaid
their debts. Consumers’ credit histories may
contain information about bank loans, vehi-
cle loans, credit card bills, student loans and
mortgages. They may also contain details
about the terms of consumers’ credit, how
much is owed to creditors, consumers’ pay-
ment histories, and court judgments or liens
against them.
“Credit history helps the consumer re-
porting agencies determine how likely con-
sumers are to repay their debts. The agencies
use that information to produce credit re-
ports and scores,” the CFPB said.
Further classifications
In broad terms, the bureau explained
consumers with limited credit histories can
be placed into two groups.
The first group is consumers without a
credit report, or the “credit invisibles.” The
second group, the “unscored,” includes con-
sumers who do not have enough credit his-
tory to generate a credit score or who have
credit reports that contain “stale” or not re-
cently reported information.
“The exact definition of what consti-
tutes insufficient or stale information differs
across credit scoring models, as each mod-
el uses its own proprietary definition,” CFPB
officials said.
The bureau indicated its newest report
is designed to shed more light on the num-
ber of consumers and the characteristics of
those consumers who have little to no credit
record at the nationwide consumer reporting
agencies. The report found that:
■ Twenty-six million consumers are cred-
it invisible: About one in 10 Americans can
be considered credit invisible because they
do not have any credit record. About 189
million Americans have credit records that
can be scored.
■ Nineteen million consumers have un-
scored credit records: About 8 percent of
the adult population has credit records that
are considered unscorable based on a wide-
ly-used credit scoring model. Those records
are almost evenly split between the 9.9 mil-
lion that have an insufficient credit history
and the 9.6 million that lack a recent cred-
it history.
■ Consumers in low-income neighbor-
hoods are more likely to be credit invisible or
to have an unscored record: Of the consum-
ers who live in low-income neighborhoods,
almost 30 percent are credit invisible and
an additional 15 percent have records that
are unscored. These percentages are notably
lower in higher-income neighborhoods. For
example, in upper-income neighborhoods,
only 4 percent of the population is credit in-
visible, and another 5 percent are unscorable
under the widely-used model.
■ Black and Hispanic consumers are
more likely to have limited credit records:
Black and Hispanic consumers are consid-
erably more likely to be credit invisible or
have unscored credit records than White or
Asian consumers. About 15 percent of Black
and Hispanic consumers are credit invisibles
compared to 9 percent of White consumers.
An additional 13 percent of Black consumers
and 12 percent of Hispanic consumers have
unscorable records under the widely-used
model compared to 7 percent of White con-
sumers. CFPB analysis suggests that these
differences across racial and ethnic groups
materialize early in the adult lives of these
consumers and persist thereafter.
This analysis was conducted using infor-
mation from the CFPB’s Consumer Credit
Panel, which is a random sample of de-iden-
tified credit records purchased from one of
the nationwide credit reporting agencies and
is representative of the population with cred-
it records.
By comparing information in the cred-
it panel from December 2010 with 2010
Census data, the bureau said it was able to
estimate the number of consumers who
were credit invisible or had unscored cred-
it records.
“Part of our mission is to empower eco-
nomically vulnerable consumers. It is hum-
bling and important work,” Cordray said.
“And in order to achieve that goal, we need
to first understand the landscape that shapes
how these consumers operate. Today’s re-
port helps shed some light on the challeng-
es they face.
“At the Consumer Bureau, we are ded-
icated to fostering a responsible market-
place that helps consumers get ahead rather
than harming them and setting them back,”
he went on to say. “We will be able to take
the information from today’s report and ap-
ply it in the future as we continue to work
on behalf of the most vulnerable consumers
among us.”
FactorTrust launches alternative data tool specific for auto financing
ATLANTA — Leveraging the possibil-
ities of alternative credit data to enhance
the underwriting process percolated sever-
al times during industry events earlier this
year. In July, FactorTrust responded to the
inherent need for increased credit opportu-
nities for non-prime consumers by rolling
out a new tool the consumer data provider
is calling LendProtect Auto Score.
FactorTrust explained the LendProtect
Auto Score is a credit risk solution for auto
finance companies and buy-here, pay-here
dealers serving non-prime consumers that is
delivered independently of the three largest
credit bureaus and is based on FactorTrust’s
alternative credit data. The core data that is
used to define a consumer’s score includes:
■ Unique alternative tradeline data
■ Application information
■ Stability metrics
■ Payment data
FactorTrust chief executive officer Greg
Rable insisted those four data points are not
available through the major credit bureaus.
Rable indicated expansions of the score this
new tool can produce are available. That ex-
pansion can include other data points such
as public records.
“The best indicator of future perfor-
mance is past performance. In the past,
lenders serving non-prime consumers have
not had a full picture of a consumer’s credit
history,” Rable said. “That changes with the
LendProtect Auto Score, which opens up
more auto credit access to millions of people
who need access to transportation.”
FactorTrust reiterated the depth of the
potential market where LendProtect Auto
Score could be useful. The company point-
ed out there are more than 50 million non-
prime consumers in the U.S. who do not
choose to use traditional credit opportu-
nities due to convenience, lack of cred-
it history or lack of a relationship with a
credit provider.
FactorTrust also referenced a study by
the Credit Union National Association,
which estimated that this same population
of people can increase their income by as
much as 25 percent if they have access to re-
liable transportation.
And to help finance companies BHPH
operators cater to this demographic and po-
tentially enhance quality of life, Rable said,
“This score is purpose-built for the non-
prime auto area.
“The consumer characteristics captured
in the LendProtect Auto Score are tuned to
the unique consumer profiles in this specif-
ic market,” he continued. “Now non-prime
consumers that have low FICO scores can
benefit through increased access to cred-
it and better rates, when positive alternative
credit history is found in our database.”
FactorTrust went on to mention that fi-
nance companies that leverage the Lend-
Protect Auto Score now can offer consum-
ers more flexibly priced loans, while at the
same time mitigate losses through the in-
corporation of alternative credit data.
Using proprietary alternative data, the
LendProtect Auto Score can capture the
highest-risk consumers in lower score
bands and promotes the lowest-risk con-
sumers into higher score bands. This pro-
cess can allow finance companies that are
working with consumers that would have
identical profiles within the three large
credit bureaus to be served more accurately.
“We are proud to offer the auto indus-
try a solution to help them better serve non-
prime consumers. Through this product we
are further establishing FactorTrust as the
leading provider of alternative credit data
for the auto lending industry,” Rable said.
FactorTrust added the LendPro-
tect Auto Score is compliant Fair Cred-
it Reporting Act and the Equal Credit
Opportunity Act.
BHPH dealers and finance companies
that are interested in learning more can visit
www.factortrust.com.
17. July/August2015 bhphreport.com 17
“For Equifax to open their doors to NIADA
members and NABD members that shows
how committed we are to this segment in
providing a platform to create a transparent
environment for consumers.”
Furthermore, the credit reporting avail-
ability is a development cheered by Steve Jor-
dan, executive vice president of the NIADA.
“Many of our members want to furnish
their consumer auto loan portfolio to a cred-
it bureau, however many are small business
operators who do not understand the pro-
cess and find it complex,” Jordan said.
“We are excited to work with Equifax
and broaden access to the process and bring
training to the space,” he continued. “Our
relationship with Equifax has really grown
over the last year, and our members will
continue to benefit from Equifax data and
industry expertise.”
Latest NIADA quarterly business
confidence survey
More of that industry expertise is com-
ing through the latest edition of the NIA-
DA Quarterly Business Confidence Survey,
which presents independent dealers’ sen-
timent on the current state of the industry.
Equifax provided insight on subprime auto
lending trends.
But a key metric from the latest survey
wasn’t connected with a bureau score.
A key statistic from the latest NIADA
Quarterly Business Confidence Survey in-
dicated that the number of dealers who ex-
pect their customer traffic to decline over
the next quarter has more than doubled —
from 8.3 percent to 17 percent — since the
survey was last conducted.
Jeffreys explained this spike reflects
heightened competition in the used market
from large dealer groups.
“The growth of franchise dealers in the
used-car space is not the only concern inde-
pendent and BHPH dealers have expressed,”
Jeffreys said. “Because many of these deal-
erships do not report their accounts to a
credit bureau, we’ve heard anecdotally that
some consumers may opt to default on an
auto loan since their credit score may not
be affected.
“To help dealerships avoid these situa-
tions, mitigate strategic defaults and reward
positive consumer payment behavior, we are
working with the NIADA to enable deal-
ers to report consumer auto loans and pay-
ments,” she went on to say.
NIADA Convention attendees learned
more about trade line reporting during a
training session at the event, which was
hosted by Jeffreys and Jenn Reid, senior
partner channel manager for Equifax, who
both have retail dealership backgrounds.
The session was a BHPH break-
out session titled, “Reporting Consumer
Credit: Advance Your Customer and Grow
Your Business.”
“It’s a matter of being accustomed to how
the report is written,” Jeffreys said. “At the
end of the day, you’re looking to interpret
the data, which is right in front of you. It’s
not rocket science. It’s just looking at it to
say, ‘OK, this customer had several inquiries
from different areas over the past few weeks.’
They might be hopping different dealers.”
Jeffreys added that being able to inter-
pret a credit report along with possibly le-
veraging the income and employment ver-
ification tools offered by Equifax can give
BHPH operators an even clearer picture of
the potential buyer.
“What we’re seeing is there are a lot of
buy-here, pay-here dealers who want to be
proactive in taking steps to legitimize their
business from the sense of creating a trans-
parent experience for the consumers and
also showing their lenders who come from
things very by the book,” she said. “They’re
verifying income and not just taking the
word of a paystub. That’s steps to show the
regulators that we’re in control of the en-
vironment and we’re doing good things
for consumers.”
MEMBERS continued from page 1
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Jennifer Reid, left, and Angelica Jeffreys of Equifax make a point during the
presentation, “Reporting Consumer Credit: Advance Your Customer and Grow
Your Business,” at this year’s NIADA Convention.
18. 18 BHPH REPORT Vol.2 No.6
By Nick Zulovich, Editor
LAKE SUCCESS and WOODSIDE, N.Y.
— While dealership management empha-
sized the settlement with the New York attor-
ney general “acknowledges no admission of
wrongdoing or liability,” Dealertrack Technol-
ogies’ Randy Henrick shared his unsavory as-
sessment of the “payment packing” possibly
orchestrated by a trio of Honda stores as well
as what the enforcement actions and multi-
million dollar penalties could mean for deal-
erships in the Big Apple and beyond.
General manager Brian Benstock re-
leased a message in June later obtained by
BHPH Report stating that “Paragon Hon-
da, Paragon Acura and White Plains Hon-
da announced they have reached a settle-
ment with the New York attorney general’s
office related primarily to their long-discon-
tinued sales of third-party credit services of-
fered by Credit Forget It (CFI). These servic-
es were broadly available to consumers direct-
ly from CFI, through automobile dealers and
other providers.
“The settlement with the attorney general
acknowledges no admission of wrongdoing or
liability by the settling dealerships,” Benstock
continued.
To recap, New York attorney general Eric
Schneidermanexplainedtheagreement,which
returns more than $13.5 million in restitution
to consumers, concludes an investigation into
these dealerships for the alleged sale of finance
office products to 15,000 consumers — items
that in some cases added more than $2,000 in
“hidden costs and fees” onto the sale or lease
price of a single vehicle.
“Paragon dealerships stopped offering CFI
credit services to customers in early 2014,”
Benstock said in his statement. “We appreci-
ate the attorney general’s office bringing the
matter to our attention and working with us
to create a positive outcome for our custom-
ers. We thank our employees and our custom-
ers for their ongoing support. It is because of
your trust in us that we are able to serve this
market as we do.”
That trust, however, could be severe-
ly damaged by this settlement. BHPH Report
reached out to Henrick, who is associate gen-
eral counsel for Dealertrack. Henrick regular-
ly offers instructional webinars and has been
a presenter at the National Automobile Deal-
ers Association Convention discussing the ad-
vertising pitfalls and other behaviors in the
finance office that draw the ire of state and
federal regulators.
“Credit repair services are always a big
target for regulators. Under federal law, you
cannot charge a customer for a credit repair
service until you’ve actually performed the
service and repaired their credit. So you
start with an unpopular product. This looks
like they were essentially payment packed
into the price of the vehicle or otherwise
misrepresented to consumers,” Henrick said.
“This was bad conduct. This wasn’t some-
thing anybody could defend as legitimate or
unintentional or a mistake,” he continued.
“Dealers know payment packing is unlawful.
They know credit repair services are dubious
at best, although they are very profitable to re-
sellers. I think having to put all of the mon-
ey into a fund, as well as pay the $325,000 in
penalties, that’s a pretty significant penalty
even if the fund is only used to allow consum-
ers to purchase additional services from the
dealerships.”
What Henrick referenced was that the
agreement requires Paragon to pay $6 mil-
lion into a restitution fund administered by
a third-party administer to be distributed to
Paragon consumers with CFI contracts and
to provide each of the about 15,000 consum-
ers with a $500 “settlement card” that can
be applied to one or more of the following
from Paragon:
■ The purchase or lease of any new or used
vehicle
■ Certain services or maintenance, such
as oil changes, tire rotations, tire repairs and
wheel alignments
■ Certain accessories, such as mats and
replacement windshield wipers.
“Paragon Honda and Paragon Acura
are New York’s premiere Honda/Acura
dealerships.Wearefamilyownedandoperated
since 1929. Our mission is to make every
customer a customer for life by consistently
providing world class service at our new and
used car dealerships,” Benstock said.
“Paragon has a friendly and helpful sales
staff and highly-skilled mechanics. We employ
people from 24 different countries who speak
22 different languages. We have won multiple
automotive industry awards including the
American Honda Presidents Award, Council
of Excellence Award for Finance, and Certified
Dealer of the Year Award,” he went on to say.
Despite that treasure trove of accolades
and a diverse staff, Henrick isn’t upbeat
about the prospect of those 15,000 customers
returning to a Paragon store.
“They’re depositing the money, but I
don’t see anything here about them getting
it back any of those unused funds. I would
doubt that a lot of the consumers who were
subject to this behavior are going to want
to deal with those dealerships. It’s terrible
publicity. It’s costly. It’s flat out unlawful.
I’m surprised in this day and age you would
see conduct like this on such a mass scale,”
Henrick said.
“This is not the (Federal Trade
Commission) coming in and declaring
something unlawful, something that
previously was mainstream, as they’ve been
doing with advertising,” he continued. “This is
just bad conduct and known to be such. I’m
not surprised by the harshness of the penalties
given the magnitude of what the sales were.
“I suspect the majority if not all of it was
payment packing,” Henrick added.
Details of Paragon investigation
The attorney general’s investigation found
that Paragon used fraudulent, deceptive and
illegalmethodstoselltheapproximately15,000
CFIcontractstoconsumers.Thatinvestigation
into the three Paragon dealerships found that,
between 2010 and 2014, they used deceptive
sales tactics, including charging consumers
for credit repair services and other “after
sale” items without their knowledge or by
misrepresenting that the services were free.
According to the investigation, and
starting in at least March 2010, Paragon
entered into an arrangement with CFI to sell
its customers CFI’s credit repair and identify
theft protection services. Every time Paragon
charged a consumer for these services,
officials explained the stores violated state
and federal laws banning upfront fees for
these services.
Afteraconsumerworkedwithasalesperson
to choose a vehicle, Schneiderman’s office
said they met with an F&I manager, who
attempted to sell them additional products
such as extended warranties, a security system
and credit repair services.
In many instances, the investigation
showed, Paragon simply charged consumers
for the credit repair services and concealed
that they were charging consumers. In
others instances, Paragon allegedly falsely
told consumers, who said they did not need
or want the services, that the services were
free. Some consumers were sold the services
without their knowledge despite the fact that
they had excellent credit.
In addition to charging consumers for
credit repair and identity theft prevention
services without their knowledge or consent,
officials said the Paragon dealers added on
charges for other after-sale items, such as
tire protection and Lo-Jack, without clearly
disclosing what they were charging for such
items. The costs of these items were often
bundled into the vehicle sale price and not
separately itemized.
“As a result, often unbeknownst to the
consumer, the price of the car stated on
purchase and lease documents was inflated
by the amount of these after-sale items,”
Schneiderman’s office said.
Why NY dealer settlement impact
might ripple elsewhere
Paragon Acura was one of three dealerships to reach a settlement with New York attorney general Eric Schneiderman
about a matter involving financing.
19. July/August2015 bhphreport.com 19
The attorney general’s investigation fur-
ther found that the dealerships failed to pro-
vide required disclosures, such as a con-
sumer’s rights to cancel the credit repair
services contract.
In addition, Schneiderman’s office said the
dealerships sometimes negotiated purchase
andleasetermswithconsumersinSpanishand
then only provided contracts and documents
in English. New York City law requires that
when the terms of an installment agreement
are negotiated in Spanish, the seller must
provide documents translated in Spanish.
The settlement prohibits Paragon from:
■ Selling, offering to sell or marketing
credit repair and identity theft services in con-
nection with the sale or lease of a vehicle
■ Selling, offering for sale, or providing
to consumers any after-sale product or ser-
vice unless, prior to such sale, certain materi-
al terms, including price, are disclosed verbal-
ly and in writing
■ Misrepresenting the price of the vehicle
in final lease or sale contracts
■ Negotiating any terms of a sale or lease
with a consumer in a language other than
English without providing a translation of
certain material documents in the language
in which the terms were negotiated before the
consumer signs these documents
■ Failing to provide consumers with
sales or lease agreements that clearly and
conspicuously itemize each after-sale product
or service and its price
The Paragon dealers, all of which are
owned by the same individuals, claim to sell
or lease approximately 1,000 new and used
vehicles a month.
Impact in New York and beyond
In recent months, Henrick has ramped
up his educational and outreach efforts, espe-
cially in light of actions involving not only the
FTC in what it dubbed Operation Ruse, but
also matters associated with the Department
of Justice and franchised stores.
“I think there’s a number of dealers who
see these things as a cost of doing business.
Historically fines and penalties against auto
dealers haven’t been of this magnitude such
that it could be a cost of doing business,” Hen-
rick said.
“These are not all dealers or most dealers.
These are a few dealers that view these kinds
of things as a cost of doing business,” he con-
tinued. “And even if they get caught, they were
having to pay very little in relation to the prof-
its, but Schneiderman here levied a very heavy
penalty, and that’s what the FTC has been do-
ing as well.”
Henrick recollected how the FTC recently
penalized a dealer who pushed buyers
into a program where they made biweekly
payments, pitched on the promotion of
saving money. Regulators found the program
didn’t save customers any money, rather it
actually cost them more, which prompted
them to say it was “a deceptive trade
practice,” according to Henrick. He said the
store eventually had to pay the FTC a fine
approaching $200,000.
“You’re beginning to see large numbers,
and I believe part of that is regulators’
enforcement philosophy that this is no
longer just a cost of doing business, that
you’re going to straighten up and do things
right or they’re going to pay a heavy penalty
that’s not going to make it economically
attractive. I think that’s the message here,”
Henrick said.
Henrick also has anecdotally heard
about the FTC currently “hammering our
consent decrees for deceptive advertising”
with multiple dealerships out West. Earlier
this year, Operation Ruse led to millions in
penalties against dealerships.
The furor of the FTC as well as the
Consumer Financial Protection Bureau
potentially is fueling enforcement officials
such as Schneiderman as well as New York
City Department of Consumer Affairs
Commissioner Julie Menin, who were
both quoted in this week’s settlement
announcement. Henrick resides in New York
so has a closer vantage point of both officials.
“Julie Menin is a very aggressive
prosecutor. She’s been on a mission against
auto dealers,” said Henrick, referencing a
program Menin’s department announced
back in April. It’s a new initiative to create
what she called a “safer” loan product
for qualified secondhand auto borrowers
and to help them “avoid financial ruin by
predatory loans.”
When asked about New York’s attorney
general, Henrick said, “Schneiderman is
showing himself to be one, as well. He’s been
very active in the securities markets and
certain other areas. This is a major foray into
consumer protection, and the dollars are large.
I think the message he’s sending is clear: If New
York auto dealers violate the law, particularly
if they violate it in ways that are indefensible,
they’re going to pay a hefty price and it’s not
going to be just a cost of doing business.”
Henrick cautions dealers who might
be far from New York about taking the
approach that what happened in the
Empire State won’t occur elsewhere. He
suspects that other attorneys general will
be discussing Schneiderman’s actions when
they gather multiple times per year for their
association events.
Henrick also mentioned plaintiff’s
associations also might be examining this
settlement to see if any class action suits can
be brought.
“You’ve got a lot of aggressive attorneys
general. Many states have unfair and deceptive
acts and practices laws that give consumers the
righttosueandrightstobringprivateattorneys
general actions. I think Schneiderman doing
something like this is going to be looked at
very carefully,” Henrick said.
“Manydealerswillsay,‘Idon’thavetoworry
about all that because I have an arbitration
clause in my contract,’” he continued. “But I
think unfair and deceptive acts and practices
claims can be separated from contract claims,
and they’re essentially statutory and tort
actions. They’re not necessarily covered by the
arbitrary class action waiver clauses. This puts
it out there.”
Henrick left BHPH Report with one last
point about this settlement and what the fu-
ture implications could be.
“It’s an extreme case, but it’s not an extreme
case because there are a small number of
dealers, but in absolute numbers they’re not
necessarily that small,” he said. “It’s not like
the old days where the fines were $1,000 or
$10,000. But we’re talking here at $325,000
penalty and a $13.5 million in restitution,
albeit some of which will be spent on services
at the dealership. But to the extent that the
money is not all used up I think it’s going to be
forwarded to the state. This is a multi-million
loss for these dealerships even under the best
of circumstances.
“This is the FTC’s and to a certain extend
the CFPB’s approach in assessing penalties,”
Henrick went on to say. “They’ve ratcheted up
the numbers substantially from where they
were just a few years ago. That causes people
to sit up and take notice. Hopefully, it will
indicate that the cost of compliance or the
practice of compliance can put a dealer in a
much better financial place than schemes like
this do.”
Paragon Honda was one of three dealerships involved in a settlement
associated with the sale of additional finance products.
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20. 20 BHPH REPORT Vol.2 No.6
HANOVER, Md. — If you are a dealer and you
have not heard that federal and state authorities
are launching a serious crackdown on advertising
violations, you must be living under a rock. For
the last several years, there has been a steady
increase in ad violation claims, with the most
recent and most attention-getting initiatives being
the Federal Trade Commission’s “Operation Steer
Clear” and “Operation Ruse Control.”
With all the publicity about regulatory scrutiny
of dealership ads, I find it hard to work up much
sympathy for a dealer who hasn’t gotten the word
and is playing ‘ad roulette.’ That was certainly my
reaction when I read the latest report of one of
these enforcement actions.
The Office of the Attorney General of
Tennessee announced on April 20 that it had
reached a settlement with a Tennessee auto
dealer that the AG and the Tennessee Division
of Consumer Affairs had charged with using
deceptive business practices to target military
families. The dealer, Wholesale Inc., agreed to
immediately change its advertising practices and
pay the state $50,000.
A county court approved the settlement among
the dealer, the Tennessee AG’s office and the Di-
vision of Consumer Affairs. The settlement agree-
ment centered around two advertising mailers
sent to would-be customers. One mailer specif-
ically targeted servicemembers living near Fort
Campbell.
After reviewing a servicemember’s complaint,
the state alleged that the dealership made numer-
ous false representations in violation of the Ten-
nessee Consumer Protection Act. According to the
state, a fictitious lender called “CreditAble Auto
Funding,” claiming to be “by military, for military,”
was offering “a limited amount of loans to military
personnel.”
Under the settlement, the dealership must
maintain proof to support all ad claims and will be
required to include the company name on all ads
sent to consumers. The dealership also must devel-
op written policies and procedures for reviewing
and approving its ads.
Nothing in the settlement agreement men-
tioned an ad agency, but I’ll bet my favorite bass
lure that this dealer didn’t dream up this ad cam-
paign, and that some ad agency has come up with
an ad program it sells to dealers located near mil-
itary bases. Some ad agencies seem to believe that
it’s OK to say anything in an ad that will bring po-
tential car buyers in the door — I’ve seen ad pack-
ages offered to dealers that seem to have absolute-
ly no regard for the truth of the statements made
in the ads. If the dealer bites and buys the ad pack-
age, those statements, of course, become the deal-
er’s statements.
If my suspicions are correct, one lesson from
this Tennessee action is clear. The authorities will
hold the dealer accountable for every ad and every
claim in every ad. They will require that the deal-
er “substantiate” each claim made in the ad. So,
if an ad describes a creditor company as “by mil-
itary, for military,” it is the dealer’s responsibility
to determine if that statement is true. If a creditor
named in an ad turns out not to exist, the authori-
ties will hold the dealership responsible for imply-
ing or stating in its ad that the creditor is real.
Another lesson is equally clear. Not only must
dealerships pay attention to federal laws like the
Truth in Lending Act and the Consumer Leasing
Act, they must also contend with the Federal
Trade Commission and state attorneys general —
enforcers of prohibitions against unfair acts
and practices.
So what should a dealership do to avoid being
in the crosshairs of the ad police? I can think of a
few things.
First, if a dealership’s ads come from an ad
agency, the dealership should do a “due diligence”
review of the agency to determine if the agency’s
ads have ever created problems for dealers. The
ad agency should be questioned about the level of
dealer compliance training, if any, its personnel
have received and should agree to stand behind its
ads.
Then the dealer should read the ads and
confirm that the statements in them are accurate
and complete. If the statements make claims,
the dealer should assume that those claims may,
at some point, be challenged, so all such claims
should be substantiated in writing before the
ads are used. The dealer should confirm that the
ads meet the requirements of federal and state
law, including, when applicable, laws regulating
merchants generally, dealers specifically, and ads
involving a lottery, a game of chance, or other
regulated activity. That sort of confirmation may
require the advice of counsel, but there are many
helpful ad compliance materials available on the
FTC’s website and on the websites of organizations
such as state auto dealer associations.
The dealer’s entire ad review process should be
in writing and reviewed by counsel and should be
updated periodically. All of these chores should be
the responsibility of the dealership’s compliance
officer.
Your dealership doesn’t have a compliance
officer? Oh my!
We need to talk.
Thomas Hudson, Esq. (tbhudson@hudco.com) is
the author of several books, and is also the editor/
author of the CARLAW F&I Legal Desk Book. The
books are available at www.Counselorlibrary.com.
He is also the publisher of Spot Delivery, a monthly
legal newsletter for dealers, and the editor in chief of
CARLAW, a monthly report of legal developments
in all states for the auto sales, finance and leasing
industry. For information, call (410) 865-5411 or
visit www.counselorlibrary.com.
Are you playing roulette with your
dealership’s advertising?
With all the
publicity about
regulatory
scrutiny of
dealership ads,
I find it hard to
work up much
sympathy for a
dealer who hasn’t
gotten the word
and is playing
‘ad roulette.’
THOMAS
HUDSON
21. July/August2015 bhphreport.com 21
The ‘bottom line’ of Spireon’s acquisition of Inilex
By Nick Zulovich, Editor
IRVINE, Calif. — Spireon chief market-
ing officer Shawn Hansen gave buy-here,
pay-here dealers and subprime finance
companies what he called the “bottom line”
about the potential benefits of the company
acquiring Inilex.
For operations that demand a GPS de-
vice be attached to a vehicle in order for
the financing and installment contract to
be finalized, Hansen highlighted that Spir-
eon clients now can pivot the conversion
to show that it’s not just about underwrit-
ing criteria. The device can open the door
to a wide array of consumer applications,
and more importantly for dealers and fi-
nance companies, the chance to generate
more revenue.
“There is a whole range of consumer ap-
plications that can be layered once the GPS
tracker is in place,” Hansen said during a
conference call after Spireon announced the
acquisition of Inilex in July.
Hansen continued that during the
past 20 years, “the IT industry in gen-
eral has been totally turned on its
head because of what’s happened with
consumer applications.
“Because of consumer demand, compa-
nies have changed their IT policies in the
way they give productivity apps to their
users. We see that same thing happening
with car dealerships in buy-here, pay-here
and subprime,” he continued. “We see that
users will benefit from additional applica-
tions they can use on their phones or get di-
rect access to. This is a very complementa-
ry fit that give the dealer an opportunity to
show where the value is to their customers.”
Through this acquisition, Spireon
now has 2.3 million connected vehicles in
its network.
“An auto finance company or dealership
who already uses GPS technology and can
offer the customer the chance to track their
vehicle can now make more money. That’s
the bottom line,” Hansen said.
“They can make more money by offering
theft recovery services and additional con-
sumer applications to the end user,” he con-
tinued. “It presents a way to increase their
profits and to add another value proposition
on top of the fact that their vehicle is being
tracked and they’re getting a loan that they
might not be able to get otherwise.”
While they might have been seen as in-
dustry competitors, Hansen indicated Spir-
eon and Inilex have had “a long-standing
relationship.” That situation led in part to
the deal.
“Inilex has been a customer of Spire-
on in providing some of the underlying
technology for them. It was a natural fit
for the two companies to come together,”
Hansen said.
“We’ve been discussing this for some
time. I’m not in a position to say how long
it was going on, but the business relation-
ship has been in place for some time,”
he continued.
Hansen noted Spireon did not face any
antitrust or regulatory hurdles to complete
the acquisition.
“This is a relatively straightforward inte-
gration of the two companies,” he said.
Hansen also mentioned a message to
any BHPH dealers or finance companies
that were solely Inilex customers prior to
this week’s developments.
“Integration is happening right now.
Sales and marketing channels are already
integrating,” Hansen said. “As far as the
technology is concerned, we’re kicking off
those efforts. We’re going to out to all of our
different dealer channels to let them know
this work is being done and will be com-
pletely relatively shortly.”
As the automotive industry transforms
in the connected car era, officials high-
lighted this acquisition enables Spireon to
uniquely connect all major segments of the
vehicle life cycle, ranging from franchised
dealers to independent and buy-here, pay-
here dealerships, fleets, finance companies,
insurance companies and rental car fleets.
They added the acquisition expands
Spireon’s strategy to offer rich services
and business intelligence across any kind
of vehicle.
Spireon emphasized that Skylink can
leapfrog traditional theft recovery services
by replacing legacy radio sets that have lim-
ited coverage with next-generation GPS ap-
plications that can be tracked with any in-
ternet connected device. Instead of relying
on proprietary technology that only works
with a small number of police vehicles, Sky-
link can offer ubiquitous coverage using na-
tional cellular networks.
And with the combination of Skylink’s
dedicated 24/7 call recovery center that
works directly with local law enforcement
and cloud-based phone applications, offi-
cials insisted that vehicles can be recovered
within minutes instead of waiting days for a
dedicated police car to search manually for
a radio signal.
“We are excited to join the Spireon fam-
ily,” Inilex CEO Michael Maledon said.
“This transaction allows us to scale our
sales and marketing efforts to reach more
dealers nationwide.
“Backed by world-class infrastructure,
our customers gain the added assurance
that Skylink will continue on our promise
to deliver high value solutions and results,”
Maledon went on to say.
Don Jasensky
800-206-6964x21
don@searchpro1.com
TWITTER@DonJasensky
www.searchpro1.com
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