Tag: CFPB

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Compliance

Documenting Processes: More than Just Compliance

Contributing Author: Steve Roennau Vice President Compliance EFG Companies
Contributing Author:
Steve Roennau
Vice President
Compliance
EFG Companies

Over the past few years, you’ve probably heard a lot about the importance of documenting your processes. Even with the changes at the CFPB, this importance is not diminished. Remember, the CFPB does not have jurisdiction over most dealerships (except Buy Here Pay Here). State Attorney Generals, the DOJ, and the FTC do. And, these government bodies haven’t undergone significant changes.

Therefore, if you haven’t already begun the process of documenting your processes, it’s time to get that project started. I’ve spoken with a lot of dealers who thought documenting processes would take an investment of thousands of dollars and a legal team. This does not have to be the case. It simply starts with taking a process that your team completes every day and writing down the steps.

Of course, with the numerous, ongoing processes in a dealership, not everyone knows where to begin. This is especially true for those processes that are simply just part of the routine. Many dealers haven’t even conceptualized how to define them beyond, “just do it”.

Just like with any big project, think about tackling this project one bite at a time. Start with the checklist on your deal jackets. Define and write down the process behind each item on the list. Each process should consist of three components:

  • What you do
  • Why you do it
  • How you do it
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Categories
Industry Trends

Your 2018 To Dos

Contributing Author: John Stephens Executive Vice President EFG Companies
Contributing Author:
John Stephens
Executive Vice President
EFG Companies

It’s that time of year again when everyone evaluates their yearly accomplishments, both personally and professionally, and begins making their 2018 resolutions. So, what were the automotive industry’s accomplishments?

Despite a string of severe natural disasters, unit sales volume is roughly on par with last year’s volume. Both 2017 and 2016 represent some of the strongest sales numbers in over a decade. That’s a win in my book.

The Consumer Financial Protection Bureau (CFPB) is beginning to be reined in by Congress. After years of lobbying for more oversight over the CFPB, dealer and auto lending initiatives are finally making headway on the Hill. Talk about another reason to celebrate!

Going into 2018, pre-owned inventories are finally right-sized for consumer demand. There’s no longer too much or too little inventory. We’re now at “just right”. Because of this, pre-owned vehicles are holding their value, and dealers have a better opportunity to increase profitability through CPO programs.

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Categories
Compliance

2017 CFPB Round Up

Contributing Author: Steve Roennau Vice President Compliance EFG Companies
Contributing Author:
Steve Roennau
Vice President
Compliance
EFG Companies

In January of this year, President Trump issued an Executive Order which required agencies like the Consumer Financial Protection Bureau (CFPB) to re-address how they issue new regulations. The order required agencies to eliminate two regulations each time they issue a new one. Because of this, we saw very little activity coming out of the bureau on issuing new regulations.

In addition, criticism of the CFPB reached a tipping point, forcing politicians to take a hard look at the powers granted the bureau. A good example of this is the Arbitration Rule that the CFPB tried to force through Congress in the third quarter. While the rule initially passed Congress, it was nullified by President Trump in November.

The latest news surrounding the bureau focuses on the change of leadership, as Richard Cordray stepped down from the position of Director. With the CFPB embroiled in internal politics, we can expect another year of limited activity. This is all great news for the automotive industry. However, it does not mean that the auto finance environment will return to the golden age of the 1980s. From an auto lender standpoint, it is no longer fiscally sound for them to undo compliance practices that are years in the making.

So what’s the plan for 2018? Essentially, stay the course! Ensure all your processes are documented. Documenting your processes does not have to cost thousands of dollars in attorney fees and man hours. In fact, it can be as simple as taking a process, like insurance verification, and writing down the steps your team takes to complete that process. You don’t need legal language. And, each process doesn’t need to be a 20-page document. It’s just writing down what you already do every day.

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