OADA NEWS - Ohio Automobile Dealers Association

OADA NEWS
The Ohio Automobile Dealers Association’s Monthly Newsletter
August 2016
OADA Town Hall Meetings Recap
IN THIS ISSUE
Over the past two months, OADA President Zach Doran and team traveled the state conducting Town Hall meetings. The purpose of the Town Hall meetings was to address various
issues impacting OADA Members directly including current legislation, legal and regulatory
issues, and to answer any questions while getting to reconnect with members outside of the
larger Ohio metro areas. Along with the legislative discussion, the OADA team was able to
expand upon the member services. Special guest speakers during the Town Hall Meetings
included 6 state legislators and a House of Representatives candidate.
1
Town Hall Meetings Recap
Announcing Next Gen Racing Day!
2
FTC Increases Maximum Civil
Penalties Effective August 1
Nominations Open for 2017
TIME Dealer of the Year
The Town Hall meetings took OADA to 8 different cities, logged over 1,600 miles on the
highway, and the OADA team met with 115 members.
In Memory of Arline Lavery
3
Ohio Family Trust Company Act
We look forward to hosting more town hall meetings around the state in the coming years! <
OADA Services: Custom Water
4
Understanding a Dealer’s Options
with Abandoned Vehicles
5
2017 OADA Convention
Ad Review: FTC Announces
Consent Order with Ohio Dealership
6
True-Up Deadline is August 15!
How to Write an Accurate,
Compelling Job Posting
7
Leveling the Playing Field:
Retail Warranty Reimbursement
8
NADA News: YES! Franchise Laws
Lower Prices and Benefit Consumers
9
Automotive News 40 Under 40
List Includes 3 Ohio Honorees
Top Legal Reminders for August
10
Safety Corner: First Aid Kits
Back to School Customer Incentives
11
Next Gen Racing Day Registration
12
Webinar: Succession Planning
13
Webinar: Retail Warranty Reimbursement
14
Webinar: Hiring 101
One of the the 8 OADA Town Hall Meetings was held in Warren, Ohio on July 20 at R.D. Banks Chevrolet. The
dealership is owned by 2016 OADA Chairman Russ Banks and OADA is grateful to Russ for extending his hospitality to host the event. Pictured to the left are some of OADA’s staff with OADA Chairman Russ Banks and his
daughter Jennifer and son Rusty.
Announcing Next Gen Racing Day!
Start your engines for the 4th Annual Next Gen Racing Day on Thursday, September 15 at
Grand Prix Karting in Columbus. Registration is filling up FAST for this exciting day of head-tohead racing. Next Gens, send in the registration form found on Page 11 of this newsletter to
confirm your spot to develop your peer network while zooming around the largest indoor supertrack in the United States! If you are a dealer and have a Next Gen in your dealership, make
sure they see get this form so they don’t miss out on the chance to join Racing Day! <
Page 1
Publisher: Zach Doran
Editor: Marie Gilman
All Rights Reserved
FTC Increases Maximum Civil
Penalties Effective August 1
Nominations Open
for 2017 TIME
Dealer of the Year
provided by Stockamp & Brown
by Deanna Stockamp & Jessica Beeman
The potential civil penalties for violating laws
enforced by the Federal Trade Commission
just went up, in some cases by 150%! On
November 2, 2015, President Obama signed
the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (The Improvements Act) into law. The Improvements
Act requires several federal agencies, including the Federal Trade Commission (the FTC),
to adjust civil penalty amounts for violations
of the laws they enforce; its purpose is to
improve the effectiveness of monetary penalties and to maintain their deterrent effect.
Now facing potential civil penalties of up to
$40,000 per day, per violation for engaging
in deceptive acts or practices, dealers need
to be more diligent that ever about their compliance efforts.
will consider when determining the propriety
of a penalty waiver or reduction for small
businesses that are not in compliance with
the law. However, any civil penalty imposed
per violation for each day that the violation
occurs can add up quickly. And, given the
fact that the maximum penalties available
under the FTC Act have more than doubled,
the civil penalties imposed going forward will
likely far exceed what we have seen in the
past. For example, if the FTC determines that
an advertisement posted on a dealer’s website for 30 days violates just one provision of
the FTC Act, it could assess a civil penalty of
up to $1.2 million.
The initial increase of penalty amounts for
2016 was determined using a “catch-up” inflation method specified by Congress. At the end
of June, the FTC announced the changes to
its Rule 1.98 to reflect the new maximum civil
penalties that will be assessed under 16 laws
for which it has enforcement authority. Effective August 1, 2016, the penalty amounts that
may be imposed under industry-related laws
enforced by the FTC will be as follows:
Keep in mind as well that the FTC rarely asserts just one violation in a complaint. The
FTC Act includes an extremely broad list of
deceptive acts and practices that potentially
covers every aspect of a motor vehicle transaction, from the advertisement of a vehicle
to the closing of the finance transaction, and
multiple violations are more likely to be identified than not. Most recently, the FTC’s enforcement activities have focused on advertising violations, representations related to
the benefits and pricing of add-on products,
and violations of the Used Car Rule. More
specific examples of potential violations of
the FTC Act include:
• Section 5 of the FTC Act: Addresses unfair
or deceptive acts or practices - Increase
from $16,000 to $40,000 per violation.
• Misrepresenting or failing to include
credit disclosures required under Regulations Z or M in advertisements;
• Section 5(l) of the FTC Act: Governs
violations of cease and desist orders issued under the FTC Act - Increase from
$16,000 to $40,000.
• Advertising prices, dealer discounts, rebates, and/or incentives as generally available to consumers, when in fact they are
limited to a select group of consumers;
• Section 621(a)(2) of the Fair Credit Reporting Act (FCRA): Governs knowing
violations of the FCRA - Increase from
$3,500 to $3,756.
• Implying that a used vehicle is “safe” by
advertising that it qualifies for a “certified limited warranty” or that a multipoint inspection has been performed
when there is an open safety recall;
It’s true that these new amounts reflect the
maximum civil penalties permitted by law
and the FTC typically does not impose the
maximum penalties for first offenses. The
FTC even noted in its announcement that it
will take into account the following factors:
the degree of culpability, any history of prior
such conduct, ability to pay, and effect on
ability to continue to do business. There is
also a civil penalty leniency program for small
businesses with specific criteria that the FTC
• Misrepresenting the price of add-on
products or failing to disclose that they
are optional;
• Advertising that consumers must meet a
certain credit score to qualify for an offer
without disclosing that a majority of consumers are not likely to meet the stated
FTC Increases Penalties
Page 2
continued on Page 7
Ally Financial and TIME Magazine recently announced that nominations are now being accepted for the 2017 TIME Dealer of the Year
Award Program. A panel composed of faculty
from The Tauber Institute for Global Operations at the University of Michigan will choose
a 2017 finalist from among the nominees in
each of the four National Automobile Dealers
Association (NADA) regions. From those four
finalists, the judges will select the 48th annual national winner who will be named the
2017 TIME Dealer of the Year at the NADA
Annual Convention in New Orleans, Louisiana
on January 27, 2017.
A TIME nominee must be a member of NADA
and OADA for at least five years. The individual should spend at least 60% of his/her time
involved in dealership affairs. OADA encourages every member to think about the ideal
candidate who can proudly represent Ohio for
this prestigious award. Visit www.timedealeroftheyear.com to find out more about the
TIME Dealer of the Year Award Program.
Please submit a written statement of the qualifications of any nominee you would like OADA
to consider. Brief biographical information
would be helpful as well. Mail information on
your nominee by FRIDAY, AUGUST 12 to:
OADA
Attention: Zach Doran
655 Metro Place South, Suite 270
Dublin, Ohio 43017 <
In Memory of
Arline Lavery
OADA sends our condolences to the Lavery
family after the passing of Arline Lavery on
Tuesday, July 26. She was 91 years old.
Arline, alongside her late husband Tom
Lavery, founded Lavery Chevrolet, Inc. in Alliance, Ohio in 1966. Both Tom and their son
Bill Lavery have served as past OADA Chairmen, in 1977 and 2014 respectively. Bill
remains a very active member of OADA and
is the owner of Lavery Automotive Sales &
Service. Arline was very involved in the community and was a loving wife, mother, and
grandmother. She will be greatly missed. <
Ohio Family Trust Company Act
provided by Schneider Downs
On June 14, 2016, Ohio Governor John Kasich signed the Ohio Family Trust Company
Act (the “Act”) into law to be effective September 14, 2106. With the passage of the
Act, Ohio is now among the growing list of
states that authorize a family to establish a
state-chartered family trust company (“FTC”)
to provide trust and fiduciary services to the
family group. Under prior law, Ohio families
wishing to avail themselves of the benefits of
an FTC could only do so if they accepted the
additional costs and administrative burdens
of operating in another state.
The new law permits a family trust company
to operate in either licensed form or non-licensed form, and a licensed FTC must meet
a series of statutory requirements. First, a
licensed FTC must have a minimum capital
balance of at least $200,000, which may be
increased up to $500,000 in the discretion
of the State. In addition, a licensed Ohio FTC
must maintain an office and at least one parttime employee in Ohio, and must hold certain
meetings and perform certain administrative
functions in Ohio. The FTC must also maintain $1 million worth of liability insurance
and is subject to periodic audits by the State.
A non-licensed FTC is generally not subject
to the above requirements, but must file an
annual affidavit with the State verifying that
the FTC is eligible to transact business as an
Ohio unlicensed FTC.
An FTC that is not licensed may only provide
fiduciary services to “family members.” The
term “family members” is defined as a class
of individuals, all of whom have a common
ancestor who is not more than ten generations removed. This common ancestor is
known as the “designated relative” and must
be identified at the inception of the FTC, and
can never be changed. Family members also
include spouses, lineal descendants (including adopted children) and their spouses, and
certain trusts. An FTC that is licensed may
provide fiduciary services to family members
and also to a limited class of non-family mem-
Page 3
bers and affiliated entities. No FTC may provide fiduciary services to the general public.
Due to an increasingly friendly legislative
landscape, more and more wealthy individuals and families are choosing to set up FTCs
rather than using traditional trust companies. Families establish FTCs for a number of
reasons, including a desire for greater family
control, privacy and flexibility. Ohio families
who may have considered an FTC but did not
wish to subject themselves to the unfamiliar
law of another state have a new option at
their disposal. Nonetheless, the Act’s provisions regarding the formation and regulation
of FTCs are extremely complex, and it is recommended that families considering an FTC
seek professional advice.
For more information on this topic, please contact either Greg L. Allison, CPA, Esq. of Schneider Downs & Co., Inc. at (412) 697-5341
or Melanie M. LaSota, CPA, Esq. of Schneider
Downs & Co., Inc. at (614) 586-7020. <
Understanding a Dealer’s Options with Abandoned Vehicles
by Kevin Shoemaker, Vice President of Legal
Affairs & Matt Chacey, Staff Counsel
Walking through the Abandoned Vehicle
Title Process
Every dealer has encountered the same problem, a consumer has asked them to make repairs to their vehicle and when it is time to
pick up the vehicle and pay for the repairs,
the consumer disappears and is never heard
from again. The vehicle ends up sitting on
your lot taking valuable space just waiting for
the consumer to decide if he or she wants
to retrieve their vehicle. The question we
frequently get is whether or not dealers have
any options to help assist them in combating this problem. The best option available
to dealers is the Abandoned Vehicle Title process outlined in R.C. § 4505.101.
Step # 1: Determine the Value of the Vehicle
Before you even begin this process, you have
to make sure that the vehicle will be eligible
to transfer the title through this law. Under
Ohio law, the value of the vehicle must be
less than $3,500.00. In order to calculate
the vehicle’s value, you look to an independent vehicle valuation guide, such as KBB or
NADA, and determine the wholesale market
value of the vehicle.
Once you have determined the wholesale
market value, you subtract the cost of any
agreed upon repairs or diagnostic charges. If
applicable, you subtract any estimated costs
of repairs to restore the vehicle to wholesale
value. Once you subtract those amounts
from the wholesale market value, you have
determined the “Vehicle Value”. That number has to be below $3,500 in order to qualify
for the title transfer under this process.
The Deputy Clerk will require that you substantiate all of these figures with supporting
evidence, such as valuation reports, repair
estimates, repair orders signed by the consumer, and any other necessary paperwork,
so make sure to include those in your submission.
Step # 2: Search the Vehicle’s Title History
and Request a Certified Copy
The BMV requires that you provide your local
Title Registrar a certified copy of the vehicle’s
Title Record when you submit your Affidavit.
Unfortunately, simply printing out a copy of the
online database is not going to be enough for
the BMV, you will need a certified copy. In or-
der to obtain a certified copy, a dealer needs
to complete Form 1173 and submit it to the
BMV. You can find this form at www.bmv.ohio.
gov/forms-numerical.aspx. This could take
5-10 days for the BMV to process, so complete
the process as soon as you can.
you send for your records as well as the green
return receipt. The local Title Clerk may require a copy be submitted with the affidavit.
The title history report gives you the names
and addresses of both the title holder as well
as any lienholders, which will be important
for the next step.
If the title holder or lienholder fail to respond
to the letter within 15 days of mailing the notice outlined in Step # 3 (as determined by
the date the post office receives the letter),
the dealer has the right to file the Affidavit and
all supporting material with the BMV to transfer the title to the dealership. The Affidavit is
BMV Form 4202. You can find the affidavit at
www.bmv.ohio.gov/forms-titles.aspx.
Step # 3: Send the Consumer and any Lien
Holder a Notice of Your Intent
Once the requested repairs or diagnostic inspection has been completed and you have
given the consumer notice that the vehicle is
ready for them to pick up, they have 15-days
to pick up the car and pay off the balance
owed before you can take any action.
If they fail to pick it up within those 15-days,
then you have to send a notice to any title
holders and any lienholder giving them notice
that the vehicle has not been picked up and
that there is an outstanding balance owed.
The statute only requires that two pieces of
information be included in the notice for the
lienholder, but we encourage your letter to
have the following information:
• That the consumer has failed to pick up
the car;
• The date the car was ready for the consumer to pick up;
• The outstanding balance owed to the
dealership for the agreed repairs;
• The wholesale value of the vehicle;
• Any applicable storage fee (unless already communicated);
• The current location of the vehicle;
• That they have 15 days from the date of
this letter to make arrangements to pay
the outstanding balance and take the
vehicle; and
• That if the consumer and/or lienholder
fails to collect the vehicle and pay off the
balance owed, you will take action that
results in them losing title to the vehicle
and any liens would be held invalid.
Please remember that this letter must be
sent to any title holder or lienholder by certified mail return receipt requested.
You should keep a copy of any certified letter
Page 4
Step # 4: Complete the Affidavit and submit
it to your local Title Registrar
A business owner or authorized agent has to
sign the affidavit on behalf of the dealership.
In the absence of a clear policy of who has
authority to sign on behalf of the dealership,
we encourage the dealer principal sign on behalf of the dealership. Remember that this
document has to be signed in the presence
of a Notary.
Also, one important thing to note, the Deputy
Clerk is going to ask you to give them a check
for the Vehicle Value (see Page # 1 for calculation). The theory behind this is that the
dealership should not be able to profit from
this type of transaction and as such you are
only going to be compensated for the costs
involved in getting the vehicle ready for sale.
Any excess funds will go to the county’s general fund and you will advance those costs at
the time you file the application.
Once you submit the Affidavit with the supporting documentation, the Deputy Clerk will
process the transfer of title and invalidate
any active liens on the vehicle. Once you get
title, the vehicle is yours to do with it what you
need to get it off your lot.
Alternative Option to the Abandoned Title
Process
If the unclaimed vehicle’s title cannot be
transferred under the Abandoned Vehicle
statute, you can still pursue an execution
action with an Artisan Lien against the title
holder. Simply having an Artisan Lien will not
be sufficient to try to take title, you will have
to initiate legal action in order to collect. If
you do have to take legal action, make sure
that the consumer is the actual title holder
of the vehicle. Remember, that in order to
maintain a priority lien, a dealer has to mainAbandoned Vehicles
continued on Page 8
Registration Now
Open for the 84th
Annual Convention!
April 21 - 24, 2017
at
OADA Convention
April 21-24, 2017
The Greenbrier
White Sulphur Springs, WV
The Convention package includes:
4 days, 3 nights at The Greenbrier
2 general business sessions (speakers TBA)
Afternoon breakout sessions
3 breakfasts
Welcome reception & dinner
Cocktails & dessert reception
Cocktail reception & farewell dinner
OADA has a fantastic group rate starting
at $259 per night (includes taxes & resort
fees) which will be honored for 3 days
prior to & 3 days at the conclusion of
the Convention.
Register online at WWW.OADA.COM
Contact Kelly Danison at 614.923.2228 or
[email protected] with any questions.
FTC Announces Consent Order with Ohio Dealership
by the FTC. The dealer will be required to
have a copy of all advertisements available
for FTC inspection for a period of five years
from the last date of dissemination.
The Federal Trade Commission (“FTC”) recently published a consent order with an Ohio
dealership related to alleged advertising violations. The FTC claims that the dealership’s
advertising failed to properly disclose credit
score requirements and whether or not tax,
title, and fees were included in the offer. The
dealership cooperated in the investigation,
admitted no wrong-doing, and was not fined.
This consent order will be in place for twenty
years from date of the order or any subsequent violations.
As a result of this consent order, the Ohio
dealer will be under higher scrutiny and the
dealer’s advertising will be regularly reviewed
“with approved credit”?
• Include a triggering term that would require specific information be disclosed?
With the growth of online and digital advertising, federal and state regulators have the
ability to review dealer’s advertising in easily accessible formats and mediums. With
the barriers to reviewing dealer’s advertising so low, we are seeing a growing number
of FTC advertising complaints against dealers. Dealers need to be cognizant about
the reality of an FTC or Ohio Attorney General complaint being filed against them and
the ramifications of those complaints.
• Include material terms, limitations, and
exclusions?
The FTC’s announcement should be a reminder to every dealer that the FTC as well
as the Ohio Attorney General’s Office is out
there regularly reviewing print ads, television
commercials, dealership websites, and internet ads for compliance. Every dealer needs
to review their advertisements carefully to
ensure they are compliant with both federal
and state laws. For example, does your ad:
• http://www.ohioattorneygeneral.gov/
Files/Publications-Files/Publications-forBusiness/Guidelines-for-Motor-VehicleAdvertising-%28PDF%29.aspx
• Utilize a layout that is easily read and understood?
There are several informative publications
that can help you educate your marketing
team and assist you in evaluating your advertisements for compliance with both Ohio and
federal law. Some good resources to help
you with advertising review include:
• https://www.ftc.gov/tips-advice/businesscenter/guidance/advertising-consumerleases
• Comply with Reg. M requirements?
• https://www.ftc.gov/sites/default/files/
attachments/press-releases/ftc-staffrevises-online-advertising-disclosure-gui
delines/130312dotcomdisclosures.pdf
• Include a statement that all offers are
• https://www.nada.org/advertisingguide/ <
• Comply with Reg. Z requirements?
Page 5
True-Up Deadline
is August 15, 2016!
Do NOT Miss This
Deadline!
provided by CareWorksComp
UPDATE! The first-ever payroll True-up period
for private employers begins July 1, 2016.
Payroll true-up reports are due to BWC no
later than Aug. 15, 2016.
At the end of each private employer policy
period (July), it is necessary to reconcile estimated payroll with actual payroll. This is
called the True-up. This report can be completed online at: http://ow.ly/4mWUlm or
over the phone by calling 1 (800) 644-6292.
How to Write an Accurate, Compelling Job
Posting that Gets You Candidates You Crave
provided by CareerCo
by Maryellen Adams, Director of Association
Partnerships
If you haven’t been impressed with the caliber of candidates that have been inquiring
about your dealership’s jobs, the first thing
you should do is evaluate your job postings.
Don’t believe it? Just try scrolling through a job
board and reading some of the generic, boring, and uninspiring listings that are out there.
It’s not easy to spot the ones that you would
apply to versus those that sound awful. If your
offerings sound mundane, lackluster, or offputting in some way, job seekers will quickly
move on to the next posting.
This new payroll True-up process is part of
prospective billing, and as a result, Ohio businesses are now required to reconcile their actual payroll annually for the prior policy year
and also reconcile any differences in premium
paid. According to BWC, the True-up allows
more accurate premium calculation. Even if
actual payroll for the year matches the original BWC estimate or a business had zero payroll, the True-up report must be completed.
In order to attract quality candidates, you’ll
need to craft a compelling job posting that
captures their attention, provides ample details about the position, and describes why
your dealership is a great place to work. And,
you have to do this working in keywords that
will help your listing show up in search results
while not getting too long-winded in detail. It
sounds complicated, but it’s totally doable.
The quickest and easiest way to True-up is
online with a BWC e-account. If you do not
have a BWC e-account you can create one by
signing on to: https://www.bwc.ohio.gov/
SelfSvcAccountAdmin/newacc.asp.
1. Start with a simple job title.
You can also complete the True-up through
the BWC call center however wait times may
be extremely high, as a result BWC encourages the use of their online reporting system.
IMPORTANT NOTE:
Again, August 15, 2016 is the due date for
your True-up report to be completed with
BWC. This is a critical deadline, as the BWC
has indicated that if a business does not
complete the True-up timely, they may not be
eligible for current, and future alternative rating and premium discount programs such as
Group Rating and Group Retrospective Rating. Once more, reports must be submitted
either online at (http://ow.ly/4mWUlm) or by
phone at (800) 644.6292.
Below are a couple of youtube video links
that you may find helpful in the process:
https://youtu.be/dmYEtuGLEnQ
https://youtu.be/YMaslG0eq-M <
Here’s how to get the job posting job done:
While it might feel whimsical and trendy to put
out a call for a “technology guru” or “social media ninja,” the job title isn’t the place to get creative. Stick with a well-recognized job title to start
since that’s the primary way your listing will be
searched for and found by job seekers. Instead, if
what you are actually looking for an experienced,
tech-savvy Delivery Consultant, be clear in the
title. Otherwise, you will attract the wrong applicants and waste valuable time sifting through
piles of candidates that aren’t the right fit.
2. Give lots of job opening details.
Before anyone will want to apply for your position, you’ll need to explain briefly what the
job entails. To attract the right person for the
position, describe your ideal candidate. Detail
the responsibilities, along with the attributes
needed to succeed. Try not to make the qualifications too rigid or you could be shutting out
potentially awesome applicants. For example,
if you are searching for a great Parts Manager,
chances are that a candidate with five years
of dealership Parts Management experience
can do the job equally as well as someone
with ten years of experience. While it is understandable that you want the best candidate
Page 6
you can find, setting unrealistic expectations
will eliminate potentially good applicants and
greatly increase your time to hire.
3. Now, get funky with your job description.
You’ve described the job, now is your chance
to sell your dealership as a great employer and
have some fun with it! Be employee-focused.
Highlight any unique perks, discuss your cool,
modern, state of the art facilities and mention
any industry-leading facts or stats. If you have
recently been named a “best place to work,”
flaunt it! What you don’t want to include here
is a whole lot of jargon or clichés about being
“a team-oriented environment that nurtures
its greatest assets.” Instead, let job seekers
get a sense of the passion that is the lifeblood
of your company. And, although it should go
without saying; be genuine. Never misrepresent the opportunity or overstate the earning
potential just to get candidates in the door.
Job seekers will see right through any fabrications, or may end up feeling misled once they
go further into the hiring process.
4. Make sure your job listing is inviting and
provides a call to action.
Hopefully by now you’ve intrigued some quality job candidates, so be sure to tell them what
the next step is. Map out how you’d like them
to apply, and give them a point of contact in
case they have any questions. And never direct them to a fax number (Can you say outdated?). Job seekers will no doubt find it inconvenient to have to fax over their resume.
While dealerships don’t necessarily need an
applicant tracking system, you should at least
have a generic email address that accepts job
seeker correspondence.
Also, be specific if you’d like them to include
any additional information or references. Getting what you want up front will avoid timewasting back and forth later on.
If you’re not sure how to approach your next job
posting, one thing you can do is check out how
others in the industry post similar positions.
Which ones would speak to you if you were the
job seeker? Which dealerships sound appealing and exciting? Those are the postings that
you should try to emulate, while being sure to
add that little bit of uniqueness that only your
dealership can offer. Once you get the formula
down, the applications will start rolling in! <
Leveling the Playing Field: Retail Warranty Reimbursement
provided by Armada Dealer Solutions
by Joe Jankowski, Managing Partner
The factory-dealer relationship is anything
but a level playing field, and unfortunately
the behaviors of some manufacturers have
necessitated state laws to protect dealers.
These laws cover a myriad of issues, but one
that is critical to your bottom line exists in 39
states, with more on the way.
For years most dealers have submitted for
annual increases to their warranty labor
rate, but have been stuck with an artificially
low parts mark-up stipulated in their dealer
agreements. This mark-up is typically 40%
over cost, although some manufacturers will
pay you list or MSRP. By the way, don’t be
fooled by the “list” claim you may hear; you
are not collecting 67%, which is anecdotally
thrown around by your factory rep, or by your
managers – you are actually being paid a
mark-up in the low to mid 50s.
Based on favorable state laws, you are entitled to collect “retail” from your manufacturer
for parts used in a warranty claim. No, retail
is NOT list price or MSRP; in most cases it is
clearly defined in the law. Basically, retail is
what your customers pay you for a warrantylike repair. In a store with typical pricing and
discounting practices, the mark-up normally
falls in the 75% to 85% range. For dealers
utilizing a list pricing model, you should expect something in the 60% range. So even in
a conservative pricing environment, a dealer
should expect to improve his warranty gross
profit by 50%; however, something on the order of doubling the gross is very realistic. This
is a one-time process, and does not need to
be repeated, unless you materially change
your parts pricing strategy.
FTC Increases Penalties
This is not to say that the manufacturer will
simply lie down and grant you a 100% improvement in your gross. First of all, the laws mandate a submission, and detail what is required
of the dealer, but that’s just the beginning.
Several things need to be considered in order to ensure the best possible result:
Thorough understanding of the law – Rest
assured certain manufacturers will read the
statute differently from you. Sometimes the
positions they take are rather shocking, including those that will simply refuse to follow
the law, or others that will attempt to include
non-warranty-like repairs in a deliberate attempt to lower your mark-up.
Following the manufacturer’s protocol – It’s
critical to understand the factory’s guidelines
for the inclusion or exclusion of various aspects of the submission; each of them has
different rules, and they typically won’t disclose them to you. If you can determine what
they are, you should follow them within reason; do not be combative, or send up “legal
signals” out of the gate.
Optimization - Absolutely key to this process
is achieving the best possible result, and
that can only be done through the proper selection of your submission sample – this is
something that should not be left to chance
or inferior technologies. Missing your markup by even a few points can cost you thousands every year, perpetually. Do yourself a
favor, and explore this aspect with some attention to detail – it will be worth it to you in
the long run.
Warranty Auditors - Beyond technology, however, is the need for a thorough audit process.
Your declaration will be scrutinized by factory
auditors that know every nook and cranny of
countering retail warranty submissions, and
you should have someone familiar with their
techniques, in order to refute their sometimes questionable positions. Here again, it
is better to get along with these folks, and in
many cases, this is not a problem; however,
without naming any manufacturers, some
are extremely difficult.
Factory Responses – In many cases your approval will not be smooth, and the manufacturer may rebut your calculations, or in some
instances, summarily reject your submission.
Responding in the proper manner is critically
important, since it could be the difference
between achieving a substantial increase in
your warranty parts gross, or obtaining nothing at all. There are many dealers that have
submitted two, three or four times over the
course of a year or two, costing themselves
multiple six figures in lost profit.
The bottom line is that you have an extraordinary opportunity to receive a fair reimbursement for the parts utilized in the warranty work you perform. If this process is
approached in a judicious and professional
manner, you can quite possibly double your
warranty parts gross profit. There are many
pitfalls for the uninformed, but tremendous
upside for those that perform the submission
process properly.
For more information, contact Armada at
(888) 259-4471 or e-mail info@dealeruplift.
com. You can also visit their website at www.
dealeruplit.com. Armada has performed over
1,800 successful retail warranty submissions to 24 manufacturers in 39 states. <
credit score;
• Failing to display or properly complete
the Used Car Buyer’s Guide;
• Failing to disclose material information
regarding biweekly payment plans; and
• Misrepresenting practices related to
collecting, sharing and/or safeguarding
consumer information.
In addition to the civil penalty, the FTC can also
seek additional amounts for consumer redress,
costs and fees, and even criminal penalties by
referral of the matter to the Department of
Justice. Moreover, the FTC will continue to adjust the penalty amounts for inflation annually
as required by The Improvements Act. So, if
you want to minimize your Dealership’s potential legal exposure, keeping apprised of legal
and regulatory developments, taking steps to
ensure that your Dealership’s advertisements,
paperwork and day-to-day sales and business
Page 7
continued from Page 2
activities are in compliance with the law, and
training Dealership employees on an ongoing
basis are a must.
Deanna is a partner and Jessica is an associate with the law firm of Stockamp & Brown, LLC.
The firm serves as outside counsel to OADA.
Please do not hesitate to contact Deanna with
any questions at (614) 761-0400 or by e-mail
at [email protected]. <
NADA News: YES! State Franchise Laws Lower Prices and
Benefit Consumers
Excerpt from NADA Chairman’s Column
A new economic report from the Phoenix Center for Advanced Legal and Economic Public Policy Studies
makes one overriding conclusion: state auto franchise laws lower retail prices of new cars, which benefits consumers.
The study, “State Automobile Franchise Laws: Public or Private Interests?” was released in July after years
of debate and speculation about the benefits of the dealer franchise network. Professor T. Randolph Beard
and Dr. George S. Ford, authors of the study, found that franchise laws do not limit competition or lead to
higher prices. Quite the opposite, they found that “all the evidence suggests there is intense competition
leading to very low margins on new car sales.” This, in turn, demonstrably lowers prices for consumers and
alters the way they buy cars and service in a very positive way.
And how does the dealer network compare to manufacturers?
Dr. Ford reports that when selling an automobile-service bundle, the analysis indicated that “franchised
auto dealers have a better incentive with respect to consumer desires than car manufacturers.” Thus, it
makes sense that state legislatures choose a market design that best fits their constituents.
Rhett Ricart, Ohio NADA Director
This latest report reaffirms the messages that the National Automobile Dealers Association—and auto dealers nationwide—have been espousing: the car-buying public is better served with our services than without.
or more than 100 years, car buyers have been relying on a system that delivers the most efficient and cost-effective way of buying a car—
through franchised dealers. Automakers contract with dealers because we incur billions of dollars in expenses for equipment and facilities; we
deliver in-person customer service you cannot get through a computer screen; and we reduce consumer costs through a competitive model
that lowers retail prices and makes purchasing possible through dealer-assisted financing.
This latest report is also consistent with what respected auto analyst Maryann Keller reported at a Federal Trade Commission panel earlier
this year. She cited empirical evidence showing that intra-brand competition among dealers significantly lowers new-car prices. A direct-sales
model would not benefit consumers in the same way. Moreover, the franchise network also promotes public safety and instills confidence in
the consumer that there is someone there to help service the vehicle when needed. State governments require dealers to invest in facilities
so that help is available to car owners throughout the life of the vehicle, and not just at the point of sale.
As regulators such as the Federal Trade Commission continue to probe the benefits of the franchise system, we urge them to remember that
the franchise laws in place not only promote competition in the free market but public safety for all. And YES, that is a win-win for consumers
and dealers alike. Visit nada.org/getthefacts to learn more about the benefits of the dealer franchise system. <
Abandoned Vehicles
tain possession of the vehicle.
After talking with several dealers about these
situations, each of them have given our office some great pieces of advice for how to
handle or these situations.
• Don’t let lienholders tell you that they don’t
have to pay any outstanding balance. The
law states that if the lienholder fails to
comply and pay off any balance imposed,
that the lien will be invalid upon transfer to
the dealership. With that said, you should
consider whether or not lowering your prices, particularly with storage fees, might be
a good idea to get the vehicle off your lot
and resolve the matter. This is ultimately a
business decision for your dealership;
• Once you send out the notices, make
sure you take some action to protect
the vehicle from being taken. Some individuals wait until you send the notice
because they believe you have stopped
paying attention to the vehicle. Once
they have taken possession of the vehicle, it makes it even more difficult to
collect on any outstanding balance;
• Remember that these titles are processed
by the individual county Clerks and as
such they may have stricter policies (e.g.
the wholesale value of the vehicle must
be determined by a specific industry valuation guide). We strongly encourage you
to consult with your local County Clerk of
Courts, Title Division office on any additional requirements they may have.
OADA strongly advises that you consult with
your legal counsel before you take any action
in getting title through an Artisan Lien.
Some Practical Considerations
Page 8
continued from Page 4
• Adding language to your Repair Order’s
disclosures that briefly outlines this process and the potential ramifications.
It should be noted that there is pending legislation before the Ohio Legislature that would
change some of the suggestions or details of
this article. If and/or when that Bill becomes
law, OADA will notify dealers of those changes
and how they impact the application process.
If you have any additional questions or concerns regarding this information, or the abandoned vehicle title process, please contact
Matt Chacey, OADA Staff Counsel at (614)
923-2232 or [email protected]. This
article is intended for general use only and
should not be considered as legal advice. All
dealers are strongly encouraged to consult
with their dealership’s counsel prior to implementing any dealership process. <
Automotive News 40 Under 40 List Includes 3 Ohio
Honorees
OADA wishes to congratulate 3 honorees from
Ohio that have been named to the Automotive
News 40 Under 40! It takes a lot to succeed
in the industry, and being named to this list
proves that they are really making their mark.
Heather Wagener (27) holds a position as
General Service Manager of Acura Columbus
in Dublin. With family in the business, she
started young, serving as a cashier in service
and answering phones. She also worked in
the parts and sales departments before being
hired into her current role. She had planned
to be a teacher, but now instead has a goal of
one day owning a dealership. Heather’s success is highly attributed to her understanding
of both her employees and customers. When
taking on the general service manager role in
2014, she noticed a lack of communication
among departments, managers, and employees was impacting customer satisfaction
scores. So, Heather instituted a weekly meeting on Mondays to get the department heads
and managers all on the same page. It allows
everyone to speak their mind and address is-
sues. There is now a stronger camaraderie
among the staff and Acura Columbus’ customer satisfaction is now at an 85.3%!
Anthony Ries (27) serves as Vice President
of Sales at Bernie Moreno Companies in
North Olmstead. He started out working a
“part time” job as a dealership sales consultant while he was a full-time student at the
University of Akron in order to pay tuition bills.
With a goal of heading to law school after law
school, plans quickly changed once he had
graduated magna cum laude in 2012. He
then met the “electrifying” Bernie Moreno,
who after discovering their many shared ideas
about how to run a dealership dispatched Anthony after only 4 months of his initial hire to
a position as general manager of a moneylosing Buick GMC dealership in Beachwood.
Anthony quickly turned the store around. By
the end of the year, the dealerships old inventory of at least 3 model years was cleared
out. In 2015, the new-vehicle sales were up
55% from the previous year. They went from
one of the bottom 10 Buick GMC dealers in
Ohio to one of the fastest growing in the Mid-
west under those franchises.
Shujaat Siddiqui (37) is the General Manager of Dave Walter BMW in Akron. On his list
of achievements is their location being rated
the number 1 U.S, dealership by BMW of
North America in 2015, based on 15 key performance indicators plus customer satisfaction scores. The dealership embraced online
selling which enabled them to outperform
larger dealerships in more affluent markets.
Shujaat said the key to his success with this
was “the fact that I had my whole new-car inventory listed with an exact lease payment.”
The result: lease penetration at Dave Walter
BWM is around 70% of new-car sales, high
even by BMW standards. Shujaat believes
in hiring the right people and working with
customers in an efficient way. Maintaining
a small sales staff only 4 salespeople, Dave
Walter BMW sold 1,289 vehicles in 2015.
Read more about the stories of success for
all of the 40 Under 40 here on Automotive
News at http://www.autonews.com/section/
underforty02! <
Top Legal Reminders for August
1. CAT Tax Quarter 2 Filing Deadline:
As a reminder, the 2016 second quarter Commercial Activities and Transactions Tax (“CAT
Tax”) return is due on August 10, 2016. Dealers can file electronically through Ohio Business
Gateway or through the ODT’s TeleFile system.
2. Disclosing Material Issues in a Used
Vehicle Transaction:
When a dealership offers a used vehicle
for sale, the dealership may have a duty to
disclose certain issues even if the vehicle is
sold “As-Is”. While there is no clear rule that
outlines what disclosures must be made, a
dealer who knows or reasonably should have
known of a material problem or issue with
the vehicle has a duty to disclose that information. The definition of “material” is very
fact-specific and depends on each individual
vehicle and/or transaction. This is especially
true if the issue is a safety related issue or
goes to the vehicle’s road-worthiness. Providing Vehicle History Reports, such as CarFax and Autocheck, is a good way to disclose
known conditions especially if you have the
consumer acknowledging the receipt of the
record. However, if the dealer is aware of an
unreported issue that could be material, they
should also disclose that issue as well.
3. Selling a Vehicle to a Tax-Exempt Entity:
In any transaction where the individual or
entity is claiming a tax exempt status, a
certificate of exemption must be completed
and signed by the consumer stating the applicable exemption. A copy of the form can
be found here: http://www.tax.ohio.gov/
portals/0/forms/fill-in/sales_and_use/exemption_certificates/ST_STEC_B_FI.pdf.
4. Using Trade-In Appraisal Forms as Part of
Your Intake Procedure:
With the growing trend of vehicle history
reports on trade-in intake, we are seeing a
number of dealers not using the trade-in appraisal form. While a vehicle history report
is a useful tool for information, it should be
used as a supplement to the trade-in appraisal form. Trade-in appraisal forms can
add an extra layer of protection of your dealership and also provide additional information that is not on a vehicle history report.
Page 9
Moreover, using a trade-in appraisal requires
the customer to state pertinent information such as collision and accident history,
odometer issues, and emissions tampering
that they are aware of, giving you information that may not have posted to your vehicle
history report. Additionally, the affirmation
from the consumer can be used as grounds
for recourse against the consumer if his/her
affirmations prove to be untrue.
5. Completing Credit Applications over the
Phone:
Dealers can take credit applications over the
phone. However, a dealer should consider
trying to guide the consumer to your dealership’s website and have the consumer submit
an application through your online portal. If
the consumer does not wish to do that, then
the best practice is to get the consumer’s
e-mail address and send a follow-up email
immediately after your conversation confirming receipt of their telephone call and asking
them to confirm the dealership has the authority to run their credit for financing. <
SAFET Y CORNER
brought to you by KPA, OADA’s Endorsed Provider of Safety & Environmental Compliance Services
First Aid Kits- A Requirement or
Recommendation? Don’t be Oversold!
by Betsy Silba
What do you really need in your first aid kit?
Some employers pay vendors to periodically inspect and supply their first aid kits.
During their visit, a vendor may be quick to
say “OSHA requires…” this, that and the
other thing. The Occupational Safety and
Health Administration (OSHA) states in 29
CFR 1910.151, “Adequate first aid supplies
shall be readily available.” OSHA goes on
to reference American National Standards
Institute (ANSI) Z308.1-1998, “Minimum
Requirements for Workplace First-aid Kits,”
to provide an example of what should be
contained in your first aid kit.
KPA recommends employers provide first
aid kits that meet the minimum requirements set forth by the 1998 ANSI standard.
Do not allow a vendor to “oversell” you contents for your first aid kit; stick with the requirements. Since 1998, there have been
revisions to the ANSI standard but OSHA
has not modified the regulation to include
the most recent revision. Vendors may
make the interpretation that since the ANSI
standard has been revised they can use this
as a selling tool to provide additional contents in your first aid kits. What the vendor
is proposing is their recommendation based
on an ANSI revision which has not been incorporated into the OSHA regulation.
workplace, there may be additional contents you want to include. Your KPA Risk
Management Consultant can assist you in
making that determination in conjunction
with local fire/rescue department or appropriate medical professionals as needed. If you choose to maintain your own
first aid kits refer to the log for guidance.
These supplies are readily available in local stores at a fraction of the price you
may be paying for vendor services.
OSHA does not “approve” the contents of
first aid kits, however, an OSHA inspector
may cite you if the contents are not adequate to respond to an injury requiring first
aid treatment.
Other considerations for first aid kits include:
Back to School
Customer
Incentives
provided by Reynolds & Reynolds
It may be hard to believe, but summer is
winding down and back to school season
is here. As students from kindergarten to
college head back to class, we all want to
make sure they arrive safely and on time.
Sometimes that requires fixing vehicle issues ignored over the summer. Help ease
the strain on family budgets by offering extra incentives for customers to bring their
vehicles in for service.
One successful way to reach current and
prospective customers is through a quality
direct mail service. Remember though—not
all mailers are created equal. Make sure
your mailers pass the test.
Pop quiz! What should you look for in a quality back to school direct mail piece?
• Size and placement- The contents
listed are based on a small business;
larger businesses may require additional volume.
• Bright, bold colors and graphics that
stand out in the mailbox.
• Availability-First aid kits must be readily available. You may need multiple
first aid kits in your facility to ensure
they are available and easily accessible to employees.
• Imagery that customers associate with
going back to school.
• Marking-First aid kits and locations
shall be clearly marked.
• Inspections-First aid kits shall be routinely inspected and expiration dates
On the First Aid Kit Inspection Log below,
verified.
you will see the list of minimum requirements and the additions that were inState regulations may be more stringent
cluded with the next two ANSI revisions.
than federal regulations. Contact a KPA
Based on the potential hazards in your
Risk Management Consultant or email [email protected] to determine
the requirements for your location.
This article is provided by KPA, an OADA
endorsed partner for Environment &
Safety services at Auto, Heavy Equipment/Agricultural, Motorcycle, RV, and
Truck Dealers. If you have additional
questions, please contact Glorianna
Cooley, Sr. Risk Management Consultant with KPA at (614) 432-5044 or email [email protected]. <
Page 10
• Coupons and offers that entice customers to visit your dealership for service.
• The customer’s name in the body of the
mail piece (other than in the address
block) to give it a more personal message.
• Promoted amenities, such as free Wi-Fi,
to make your dealership more attractive.
• Clearly listed service department hours.
• Easy to locate contact information including phone number and website.
Prepare your specials early to capture as
many customers as possible before they
head back to school. Utilize your customer
database and available lists to reach the audience most likely to take advantage of your
offers.
Create an A+ direct mail piece that promotes
your dealership as the best source for back
to school service—contact your Reynolds
Document Services Consultant, call (800)
344.0996, or email [email protected]. <
4th ANNUAL NEXT GEN RACING DAY
SEPTEMBER 15, 2016
10 am - 3 pm
GRAND PRIX KARTING
1300 Alum Creek Drive, Columbus, OH 43209
Presented by:
Sponsored by:
A day of FAST racing fun!
1/2 mile indoor supertrack
On-track racing, head-to-head with fellow Next Gens
Develop your dealer peer network
Special guest speaker TBA
Please adhere to the dress code:
Closed-toed shoes are required
Loose hair must be pulled back under helmet
REGISTER TODAY!
Space is limited due to the number of driver’s seats available. This event filled up last year, so act fast!
Name: ________________________________________ Dealership: __________________________________________________
Cell: __________________________________________ E-mail: ______________________________________________________
Cost: There is no cost to attend the event, but a $200 contribution to Legal Defense Fund OR a $150 contribution to DIG
(Dealers Investment Group) is encouraged.
I wish to contribute to:
Legal Defense Fund ($200)
Check Enclosed
DIG ($150)
Please Charge Card #: _________ _________ _________ __________
corporate or personal funds acceptable
MUST BE a personal check or personal credit card
Expires: _______ / _______ Security Code: ______________
Please return to: Kelly Danison at [email protected] or fax to (614) 766-9600
If mailing with a check, send to: OADA, Attn. Kelly Danison, 655 Metro Place South, Suite 270, Dublin, OH 43017
Questions? Call Kelly at (614) 923-2228
Dealership Succession
Planning—Moving Metal
to the Next Generation
OADA
655 METRO PLACE
SOUTH, SUITE 270
DUBLIN, OHIO
43017
Tuesday, August 9,
2016
11:00am-noon
Tel: 614-923-2231
614-766-9100 x109
800-686-9100
There is a $30 connection fee for OADA
member dealers. Nonmembers will be charged
a $50 connection fee.
OADA Brown Bag Lunch Webinar Series
Many owners have the pleasure of witnessing family members work in their dealerships. Owners generally find great satisfaction in watching these family members develop both personally and professionally through a business they cultivated to become
not only successful adults, but also next generation business owners. At some point,
when (i) these family members have developed the requisite skills and/or (ii) owners
are looking to completely or partially exit, a transition of control and ownership will
occur.
OADA invites you to join us as we host Greg Allison from Schneider Downs & Co.,
Inc., Pittsburgh office, as he instructs you on how to prepare for this transition. From a
high level, this transition may seem like a simple process—the owners will transfer
control to certain family members when he or she is ready. However, this approach to
succession planning is like driving to a new destination without a map or directions.
With much good fortune, the adventurer may end up at his or her destination with no
issue. However, chances are you will become lost, waste time asking for directions,
stop for an extra tank of gas, and arrive late, embattled, and lighter in the pocketbook.
This webinar will take the form of a one-hour estate and succession planning case
study involving a fictitious dealership. It will begin with the initial meeting with the
owners where succession planning first surfaces and will end when the last share of
stock is transferred to the next generation. We will explore the many different issues
that commonly arise during this process such as:
 When to transfer voting stock
 When to transfer nonvoting stock
 How to provide for children that are not in the business
 What role trusts can play in this process
 How the federal estate and gift tax and impact this succession plan
Dealership Succession Planning—Moving Metal to the Next Generation
Name (s)
Dealership
Email (s)
Phone
Method of Payment
Visa
Bill Me
MasterCard
Check
American Express
Signature
Webinar
$30.00
Link to Electronic Recording
$20.00
DVD Recording
$20.00
Credit Card #
Exp. date
sec code.
Retail Warranty
Reimbursement—A
360 Degree View
OADA
655 METRO PLACE
SOUTH, SUITE 270
DUBLIN, OHIO
43017
Wednesday, August
17, 2016
11:00am-noon
OADA Brown Bag Lunch Webinar Series
Forty states, including Ohio, now allow for warranty claims to be reimbursed at
“retail.” That’s where the simplicity ends, and the complexity begins. Join OADA
and our newest endorsed partner, Armada Dealer Solutions, as we bring you this
FREE webinar, which will explore this topic in detail.
This webinar will define the opportunities, the challenges and solutions in an area
that may just be one of the most misunderstood subjects in the retail automotive
industry.
This webinar will demystify the:
Tel: 614-923-2231
614-766-9100 x109
800-686-9100
There is no connection
fee for OADA member
dealers. Non-members
will be charged a $50
connection fee.

True definition of retail (it’s not MSRP)

Inherent complexity of the new law

Manufacturers’ submission protocols

Process of Optimization

Factory warranty managers’ techniques

Manufacturer push-back and resolution
In addition, the criteria for deciding whether to perform this process in-house, or
to outsource it, will be covered in detail, including the “need to know” for vendor
selection. This will be an unprecedented, comprehensive deep dive into this subject
matter, and it will dispel the myriad of myths surrounding it.
Our presenter for this topic will be Joe Jankowski, Managing Partner for Armada
Dealer Solutions. Armada is a firm specializing in Retail Warranty Reimbursement.
With over 1,800 clients in 39 states, Armada is by far the leader in providing retail
uplift services to automotive dealers.
Retail Warranty Reimbursement—A 360 Degree View
Name (s)
Webinar
FREE
Link to Electronic Recording
FREE
DVD Recording
$20.00
Dealership
Email (s)
Phone
Method of Payment
Visa
Bill Me
MasterCard
Check
American Express
Signature
Credit Card #
Exp. date
sec code.
Hiring 101—What You
Can Ask, Should Ask,
and Should Never Ask
OADA
655 METRO PLACE
SOUTH, SUITE 270
DUBLIN, OHIO
43017
OADA Brown Bag Lunch Webinar Series
And How to Create Defensible Hiring (and Firing) Decisions…
Monday, August 19,
2016
11:00am-noon
Tel: 614-923-2231
614-766-9100 x109
800-686-9100
There is a $25 connection fee for OADA
member dealers. Nonmembers will be charged
a $50 connection fee.
As part of our ongoing effort to provide members with practical assistance in managing their employment law concerns, OADA and Fisher Phillips are offering this webinar to help address issues related to hiring and retention. In this presentation, we’ll
discuss issues frequently raised by dealers through the OADA legal hotline. This webinar is for anyone who participates in the hiring process. Topics that will be covered
include:
 What questions can you ask an applicant, and which questions are off limits?
 How can you ensure you are hiring assets instead of liabilities?
 What recent changes in the law affect the hiring process, from employment applications to post-hire questionnaires?
 How do you handle it if a background or driving check shows a problem?
 Practically, how do you create documentation that will withstand legal
challenge?
 What are the “warning signs when hiring,” how can you identify, interview, and select the best candidate while avoiding legal liability?
 How do you protect your dealership from EEO violations and discriminatory practices?
 What are the pros and cons of implementing background checks, aptitude
tests, drug testing and/or physical exams?
Melanie Webber, a partner with Fisher Phillips Cleveland Office and a frequent
OADA presenter, will facilitate this webinar and take your questions. Fisher Phillips
serves as labor and employment counsel to OADA and provides members counseling
regarding employment issues through OADA’s legal hotline. The firm’s practice is limited exclusively to the areas of labor and employment law representing employers.
Hiring 101—What You Can Ask, Should Ask and Should Never Ask (and How to Create Defensible Hiring—and Firing—
Decisions)
Name (s)
Webinar
$25.00
Link to Electronic Recording
$20.00
DVD Recording
$20.00
Dealership
Email (s)
Phone
Method of Payment
Visa
Bill Me
MasterCard
Check
American Express
Signature
Credit Card #
Exp. date
sec code.