Auto dealerships should train employees on compliance, governance and risk every month and have personnel sign documentation they will behave properly, says Tom Kline, founder of compliance company Better Vantage Point.
"Then, when challenged by a regulator or lawyer, the dealer can argue that any incident with an employee violation of these policies would be an anomaly," Kline writes. "It's not a pattern and the dealership can prove he educates his staff to ensure compliance with all laws and regulations."
One dealership compliance form provided by Kline describes a state regulator's allegations of deceptive finance-and-insurance practices at a different retailer and has employees commit to avoid that specific behavior. The employee must sign off on the language, "The Company expressly forbids any misrepresentations, inflation of customer income, or the changing or forging of any documents signed by the consumer. Misrepresentation, falsification and/or forgery…