It’s the letter, email, phone call or physical visit that no one wants. An auditor from the Federal Trade Commission (FTC) is visiting your dealership to conduct a formal audit. Whether responding to a specific complaint or conducting an area-wide investigation, auditors mean business. Ignoring the notification – or downplaying the occurrence – is not an option.
But what got their attention in the first place? Most audits stem from unaddressed consumer complaints. For example, the Consumer Financial Protection Bureau (CFPB) states that it has increased its focus on regulations and enforcement actions in large part due to the increase in consumer complaints. Consumers submitted almost 500k complaints to the CFPB in 2021, 800k in 2022, and over 1 million in 2023.
While not every consumer complaint is the result of a compliance failure, agencies such as the FTC and CFPB do analyze the complaint data as an early warning system for potential regulatory issues. A large volume of specific complaints can influence policy decisions.
What can you do to stay off the auditor’s radar?
For a dealer principal, analyzing trends in consumer complaints from your own business is crucial. The exercise not only helps address compliance issues in real-time, but it also helps your managers evaluate the performance of your staff and systems. Customer service has become an increasingly significant focus for all regulators. How promptly and effectively you respond to your customers can greatly assist in mitigating audit and compliance risks.
Where are the complaints?
The first place to look is, of course, your Customer Service Index (CSI) score with your OEM. Outside of that, pay close attention to your dealership’s online reviews on sites like Google, Yelp, DealerRater, Cars.com, Edmunds, etc. Each review, whether positive or negative, needs a prompt response. Thank positive reviewers and take the negative conversation offline while investigating those reviews. A good rule of thumb is to track all reviews across all platforms to uncover trends in both positive and negative service. This should be one of the primary responsibilities of a dealership’s compliance officer.
Learn more about the benefits of tracking complaints in our podcast here.
What if I do get visited?
Hopefully, your compliance procedures are well in hand and staff is practicing good habits. If you are tapped for a formal compliance audit, here is a basic checklist in preparation for the big day.
- Written processes – Be prepared to provide them with all your written process documentation. It’s not enough to ‘say’ you practice good compliance. Regulators require written processes and documentation of completion for every transaction. If your processes are older than one year, spend the time to bring them current.
- Documented formal training – If you have invested in formal training, pull those records noting everyone who completed the training. And if you haven’t invested in formal training, be prepared for individual employees to be questioned about their understanding of the rules and regulations.
- Regular process audits – The auditor will ask for proof that your dealership is conducting regular internal audits to make sure your training and processes are being followed, as well as documenting the steps implemented once those audits are completed. Not conducting internal audits? Be prepared to endure additional questioning and make a note to quickly implement this task.
If this all sounds challenging, EFG has developed a simple eBook to help you take a common sense approach to compliance. Download it here.
Like any well-implemented habit, compliance efforts can quickly become an easy part of the daily activities at your dealership. We’re here to help. We offer a great compliance health check that can provide useful insights that not only get you ahead of the compliance 8-ball but also improve your customer experience and increase your profitability.
At EFG Companies, we’re experts in compliance and training. We’re more than an F&I provider, we’re your business partner in the retail automotive industry. Contact us today to learn more about how our team can help you achieve your winning strategy.