#270 - Are Regulators Making Up Rules w/ Shaun Peterson

You are listening to the Independent Dealer Podcast with hosts Luke Godwin and Jeff Watson.

Hello and welcome to the Independent Dealer Podcast, brought to you by Buckeye Dealership Consulting. This week, Luke, we are talking legislative policy updates. I'm actually in D.C. right now. You wouldn't know it by the boring background I've got, but. But I'm in D.C. for another legislative rally.

But it got us thinking.

Thinking we haven't talked to our good friend Sean Peterson in a really long time.

Yeah, it's great. Yeah. Sean is, is the guy. When it comes to what's going on in D.C. what did car dealers need to do to just be aware of the policies that that crazy legislation may lead to or just, you know, the wrong. The wrong group in lead and DC can lead to a bunch of craziness for us cardigans. So, Sean, thanks for being with us. This is probably like your 20th time on the Independent Dealer Podcast. We really appreciate it. How's it going, buddy?

I'm doing fantastic. So do I get a frequent flyer punch card? Like if, you know, 20 appearances, get one free kind of a thing? Is that.

I think. Yeah, I think so. I think we can do that.

You know, we always go to the smartest guys, so that's definitely something to be said. When we need good, accurate information, we call up.

Sean, it's always great to be with you guys. I appreciate the invitation.

Well, Sean, what. What should we be worried about? What's the top thing we should be worried about right now?

Well, there's so much that's going on. It's interesting to me, you know, from a political standpoint, maybe it's. It's good. Kind of set up the politics right now. Right. So, you know, we, we have a Democrat controlled White House. Everybody knows that. We have a split Congress. Right. We have a Republican controlled House of Representatives, we have a Democrat controlled Senate. Now, interestingly enough, you know, I have a couple of senators on the Democrat side that have battled some health issues. So, you know, nothing's really happening from a Senate perspective in large part because it's hard to call up votes when you have a couple of folks on the bench that could ultimately swing the vote the other way. So there's just not been a lot of activity in the Senate. And on the House side, you've got an active House of Representatives that's really kind of an investigation mode and oversight and hearing mode is to kind of pull apart some of the things that they've disagreed with over the past couple of years of a Democrat controlled House of Representatives. So there's not much that's going to happen, I don't think from a congressional standpoint. But, but why I say that is it's important to know that in my opinion, that's actually going to embolden the agencies that we deal with. Right. So we've actually seen a lot of activity. So what's the most important thing going on? Man, that's hard. Hard to tell. There's. Because there's so much that's going on by way of proposed rules, by way of agency enforcement actions. Let me start with this one, though, because I think this is an interesting one for, for the, the listeners on this particular podcast. We know that we've all been battling the CFPB for a very long time, right?

At least 10 years, right?

Yeah. He's been in existence now for about 12 years. And part of the challenge, those of you that have, have been with us to, to Washington in years past, where we have taken issues about the CFPB's organization and whether it's constitutionally structured properly. There's been a lot of legislation that's been proposed that would, you know, create a, a rejigger the, the bureau so that you have a, a bipartisan commission of multiple commissioners as opposed to one director that they have now and have a, a budget that's subject to congressional appropriations like almost every other agency. Right. We battled that issue a lot. Never got anywhere congressionally.

Right.

It would.

The Democrats just weren't in favor of it. Let it go. The Republicans, you know, could never get things over the finish line across, you know, all the way across the board. So there's been some significant court challenges in the past.

Right.

The CFPB here, several or, sorry, the Supreme Court several years ago had a case that the issue of whether or not this, this one bureau or one director in charge of the Bureau was something that was constitutional or not. And ultimately they said, not really, but we're going to allow one director. He just cannot, you know, have these protections that were originally built in where he could not be removed. And so we know that that case is, has, has finalized. We, we still have the one director model, but he can be fired by the president at will like any other, you know, Cabinet head, so to speak. But the Supreme Court here in the last couple of months has taken up the second issue as to whether or not the CFPB is constitutional based upon this funding mechanism. So right now, the CFPB's budget is just given to them as a portion of the, the Fed's budget. Right. So here's a chunk of money. Go do your thing. And the, and, and the opponents to that model say, well, there's no oversight, there's no control. There's no, you know, the people don't have a say what's going on. Whereas virtually every other government agency is subject to Congress, you know, appropriating the money, saying, all right, we're going to give you this. And you guys both have kids. I have kids. Luke's kid is, you know, getting to this point now where you get to teenager mode and Jeff will relate to this.

Right.

What's the number one way to, you know, kind of control the kids these days?

Probably social media, I would think.

I'm gonna take away your money. Right. It's, you know, you can have the phone. Oh, yeah, I'm not gonna pay for that anymore. There's no way.

Right.

Especially as the kids get older. Hey, dad, you know, can you. Well, that's ultimately what, what we've got going on here right now is, is Congress, the House Republicans especially, want to be able to say, no, no, no, no, no. We get to decide whether or not you get the money or not. So the Supreme Court has had oral arguments on that case. A lower court found that the, the organization and the funding mechanism is unconstitutional. The CFPB appealed to the Supreme Court, and Supreme Court decided to take the case. We expect a ruling sometime here in the next, probably six weeks. Usually these big rulings are released in June. So it will be very interesting to see what happens with the current court structure and that decision. I would expect, if I'm shaking my crystal ball, I would expect that there's a strong possibility this court will say it's not a constitutional mechanism. Then the issue becomes what happens to the Bureau.

Right.

That's, that's what I was about to ask me. What if that is actually come, come to pass? I mean, does it shut down immediately or does funding stop? What can happen?

Well, I, I, that's going to be interesting. You know, the, the, the attorneys that I've talked to that are kind of watching all this with me, you know, we have differences of opinion as to whether or not, you know, it's, it's, what's the remedy? How does the court fashion a remedy? I would be absolutely shocked beyond shock if the Bureau goes away. So I could certainly see a mechanism where, in essence, the, the past actions of the Bureau are in essence, ratified, you know, tacitly by the Supreme Court. I don't know that they'll Ever come out and say, you know, so let it be written so to be done, that everything in the past is legit now because. But I think that you'll have some kind of a, A remedy. Again, this is just me shaking a ball. I think you'll have some kind of remedy where the court will say, hey, that's unconstitutional. Funding has to be subject to appropriations like any other mechanism or any other agency out there, most of the other agencies anyway. And the Bureau will just continue to go on and, and then it becomes a battle as to whether or not there's funding.

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Before the cfpb, I mean, who was that oversight? Who, who handled that? Because I just remember, I mean, maybe when I first got involved with, you know, with an idea and everything, that it was big was the first thing before that who had oversight over what was going on with, with lenders. Yeah.

So most of, most of that sort of stuff fell into two things. Right. On the consumer protection side of it, you know, regulating the dealership and the trans motor vehicle transaction itself, the FTC largely had jurisdiction for, for big, you know, banking sorts of issues and lending sorts of issues that depended on what kind of financing entity you were. There's entities, OCC was an entity, there's the, the Fed, the Federal Reserve Board, you know, all those sorts of things depending on where you, you fell into your organization, banks would come here and other finance companies may come over here. And it depended on what the transaction was. And part of the reason the CBB came to existence is because there was this perceived lack of clarity or lack of pinpoint accuracy of you're doing this and you're doing that, and we're going to tighten things up.

Did this stem from the, the, the housing crisis in 08? I mean, is that where that came from?

A large part of it that was Kind of the jumpstart to a lot of this was or finalizing it, right? This is a brainchild that had been around. Elizabeth Warren had been working on this for years prior to the, at least the concept, years prior to the, to the mortgage crisis. But that certainly was the accelerant to get things done.

Do we, do we feel like the last two months of banking semi banking crisis will lead to some more power from the CFPB or from other agencies because of this I don't think you'll.

See anything again from a congressional standpoint. I don't think you'll see that in large part because you've got divided government. But I do think again these sor real time issues are what emboldened the agency to take specific actions. And if you see what the CFPB has done here in the last six months, there's been some interesting things from, from an enforcement side, from a rulemaking perspective. Give a couple of different examples here. Just in the last two weeks or three weeks, those of us that have been around for a while, we, we've heard this concept of, of udac, right? Unfair deceptive and abusive acts and practices, right? Every state has some version of what we call UDAP statute. Federal government has now had created that in the form of what the FTC can do and what the CFPB can do by giving it various UDAP authority. One of the things that has always been an amorphous thing is this idea of well, what's abusive state level that concept never really had had existed before. At the FTC level it never had really existed before. But when Dodd Frank created the CFPB and gave them UDAP authority, they created that extra A. Not only did they have unfair deceptive, they then added this abusive but it never been defined. So here the CFPB in the last couple weeks put out a guidance document and I'm all for guidance. I think guidance is good when it's reason. And they put out this guidance document that some would argue isn't reasoned. It, it tries to define what abusive is and it you know, includes things like if you know, if you're hiding things, if you're playing shuffleboard with, with terms and you know, explanations are unclear, those sorts of things, right? That you're, you're putting yourself in a position where you're truly taking advantage of, of a consumer because you're in a higher bargaining position, let's say those sorts of things. The issue ultimately comes down to the, the objection that a lot of people have to this statement Is again it comes down to who's the prosecutor.

Right.

The CFPB director is ultimately going to be the one to say I think that's abusive. And it, even though they try to put some parameters around that, it ultimately becomes a, well, we think this is abusive so we're going to go with it, you know, a whim one kind of thing. So it'll be interesting to see how like that plays out in enforcement actions. One of the other things that we've seen here over the last couple of months from CFPB is really stepping up. A couple of key issues will be really important for buy here pay here dealers. The CFPB has in their supervision and examination of banks and larger finance companies that they have the ability to go in and rip apart books and kind of check out every angle of the operation. We call that supervision under supervisory authority. They've, they pointed out, we've seen some of these banks and finance companies make some mistakes in how they repo vehicles, improperly repoing vehicles when they shouldn't have been doing that. They specifically pointed out to, you know, several instances and reports that they released and they don't name names of banks. They just say here's the issue that we spotted. You know, particular finance company may have made a deal with the consumer and you know, agreed not to repo. And that message doesn't get back to the repo agent. Targets taken. Anyway, we have problems. The other thing that we've seen in that particular world is an improper credit of fi product cancellation. So for example, there's a service contract or that can or gap particular product and there's a credit due to the consumer either hasn't been given inaccurately given those sorts of things. They're starting to ramp up on those issues. Last thing that I'll mention, which is very interesting and kind of speaks a little bit I think to the hubris of the CFPB in a lot of people's eyes is they issued a proposed rule, I affectionately call this the tattletale rule. But they are proposing a rule that would require certain entities again that they have supervisory control over to in essence report on themselves. You got to tell the CFPB when you screwed up, whether it was intentional or unintentional and you're subject to some of court order or state administrative action or something like that. You have to tell us all the sorts of things that you've done wrong. Debate does that create constitutional issues? But you know, we all have kids. How many of our kids are going to come and tell us they screwed up, right?

Hey, everybody, real quick, buy here, pay here, United. If you jump online right now, the day you're listening to this and get signed up, you can still make it out to Vegas with us at the end of the month and have a good old time rubbing shoulders.

It's gonna be great. Jeff and I are gonna be there. We do a lot of interviews. We look forward to seeing everyone there. We want you to come up to us, say hello, get on the camera. You'll be famous like we are. And. But buy here, pay here, united.com. it's the summit at Bellagio. Sean says there's still a couple cheap hotels left if you need them, so reach out. Let's get it done. So, you know, I've always. Are you like, okay, we should, we should pay attention to this. Sean and I get it. And we spent a lot of time in Washington talking to CFPB and, you know, talking to legislators, trying to get this, you know, I guess, right sized.

How.

How much should a buy here pay here dealer who has 2,000 or less accounts? I mean, or maybe a thousand or less accounts? Should we really worry about the CFPB knocking on our door tomorrow? Are there bigger fish to fry?

That's a great question, I'll tell you that. We've actually seen the CFPB take some shots at smaller dealers, Right. There was a case many years ago out in Colorado with a smaller buy here, pay here dealer.

Is.

Is it likely that the CFPB itself is going to come knocking on the door? Not probably, very likely. But what happens is when the CFPB creates these big, broad concepts, right? What is abusive and, and then they put together proposed rules or they even take enforcement action. We talked about this concept years ago when the CFP was first born. We called it regulation by enforcement. You may have heard me say that in the past. Right. In essence, it would. They would take a. A lot of times a company that really couldn't defend itself, put them under some kind of a consent decree and then broadcast to the world, we did this. And now we expect everybody else to. To live up to the same kind of, you know, prescriptions and, and requirements that we put into this order for this particular company, we're starting to see some of that. We feel like that's coming up again. So we may not, you may not see the, the CFPB itself knock on the door, but state attorneys general that rely upon what the CFPB do, that's a stronger likelihood. Plaintiffs attorneys that rely upon what The CFPB has done, that's an even stronger likelihood. So the one thing I want to make sure that dealers understand is just because you yourself may not be, you know, in the crosshairs of the federal agencies, this would be true of the FTC as well. That doesn't mean that I don't have to make compliance an important part of what I do. Because what happens around you locally, right. We all know plaintiffs attorneys that are circling nearby, the state attorneys general, consumer protection agencies, others circling nearby that will be ready to pounce if you don't do it.

Right?

I mean that's, that's the real rob. I mean, all of us have to worry about our state, like in Texas, O Triple C or in South Carolina Department of Consumer affairs, we have to worry about those agencies. But what really scares me is a plaintiff attorney all of a sudden coming in because I didn't refund something right, on a repo and just hammered me across the board with the class action. I mean, there are protections, arbitration agreements and things like this, but I mean, that's where people should be worried.

What I find is I never want to be, I never want to be doing something that I see in the headlines, right? Because like if it's in the headlines and it's in the news, those are like the hot topics. They're like the whack a moles that, you know, some regulator, some plaintiff attorney is going to get into. So if I'm the one participating in, you know, dealer markups or if I'm participating in, you know, abusive products, back end products, or all these little things that you see kind of coming up in the news right now is like where dealers are, quote unquote, taking advantage of consumers. I just want to make sure I'm as far away from that as possible, you know.in my eyes, crossing my T's, abusive interest, abusive repo practices, data breaches, like all stuff I don't want to be anywhere near.

And these, and these fees, right, they're real. FTC is really worried about fees.

Well, so it's interesting you talk about fees because that seems to be the buzzword of the administration right now, right? Junk fees. I mean, I've seen the president refer to junk fees in, you know, these little impromptu press conferences that he does on the, on the south lawn before he gets on Marine One to where, where we said. Right, but we've seen that, that term pop up in FTC nomenclature. We've seen that term pop up in the CFPB nomenclature and you know, I'm sure that's something that will, will continue to be around because, look, one of the things that you know it, both in politics and in law, you know, you're going to grab on to things that will make, make your argument sound sexier, right? And that's, oh, these are junk fees. Well, let's build something around that. And interestingly enough, you know, the CAPB's got some definitions of what you know. And again, it's all loose stuff where they've kind of woven this into some of the things that they've done. The FTC here in September, I guess was last summer. Comments were due in September. There's a proposed rule that the, that the FTC is working through right now that will apply to car dealers. Now, I'm going to come back and kind of COVID who it really applies to because I think there are some, some loopholes that are interesting. But they proposed a, a rule that's intended to cover kind of the, the entire scope of the automobile transaction. And it's, it's really a, a swing and a miss in so many different ways because they just don't understand the complexities and nuances that go into the transaction. When they release this proposed rule, again aimed at trying to curb these junk fee concepts that they're trying to shove certain legitimate things into. This concept of the, well, that's a junk fee, or has to potentially be a junk fee that when they released this proposed rule, they, they were, they're trying to do it under the guise of, well, you know, we're going to make the, the customer buying experience better, clearer, shorter, that sort of stuff. And when that, what they put together and released does nothing of the sort there. This proposed rule would require dealers to jump through significantly more hoops. Right. It'll be more paperwork for the consumer to sign. It'll be more disclo documents. It'll be, you know, how long does the normal closing take for you guys? Right? You know.

Yeah, 20 to 30 minutes.

If you could do it in 30 minutes, I think everybody's doing part wheels, right? This has the potential to double it.

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It's, it's, it's longer. This is no lie. And I've closed on some property and some different loans lately.

It took.

It takes longer to do a car loan and car sale than it does to buy a $3 million piece of property. And I'm sure they can make it worse, right?

Yeah, 100%. So I'll give you a specific example. One of the things that they're, they're going to require if this rule goes through as is is you have to disclose and they have this defined term called the offering price. So and it's the full cash price at which you're going to sell or finance the vehicle minus these, you know, any government fees, taxes, that kind of stuff. So you have to disclose the offering price pretty immediately. So the FTC tries to disclose when. Well, and they put things out there. Well, you have to disclose it in any ad that references a particular vehicle, any ad that represents a monetary amount or of a financing term, any communication with the consumer going back and forth about those sorts of things. So if you have the little chat bot on your website, let's for example, right. Hey, I'm interested in. Well, boom, there's that offering price has to be given. Customer calls you up or sends a text message to, to the. Boom, you have to. And if they start to do that on. Well, I'm interested in, you know, F150. I'm interested. And you have four F150s on the lot. Well, you have to provide this at four times. But if you provide it in writing, it must be disclosed in writing and the customer has to sign it. I got it. Well, yeah, more paperwork that just. That doesn't have anything. Here's another thing that's interesting about this particular proposal is you'll have to create what we call an add on list or what the FTC is calling it out on list. Right. So if you have various F and I products, voluntary protection products that you're offering, you have to provide an entire list of all of that stuff. But here's where it really gets from a definition standpoint, bogged down. If you're in the weeds of, you know. Well, I shouldn't say, let me rephrase it if you're offering not just F I products but you have other, let's just say aftermarket sorts of things that you're going to sell. The custom. Right. Mud flaps, you know, F150, the hunt, you know, nice little spotlights or whatever, the you know, bumpers.

Yeah. All that undercoating.

Yeah. You name it, gotta list it. Your add on, your add on list has to have that and that has to be published and you have to keep that up to date. It becomes an administrative and paperwork nightmare. And it's all based on this idea of getting expressed informed consent. Right. We want the consumer, this, the FTC talk and we want the consumer to have expressed informed consent on all the things that they're buying and, and participating in. And well, you have to provide that again, like I said, every single time. So your deal jacket, that was 25 pages before. Oh my gosh, think about how many more times, how many documents that are going to go in there. It's, it's a challenge. And here's what's interesting and, and to me one of the ultimate issues with this proposed rule, the ftc and, and I'll, I'll talk at talk about it from the context of, let's say you're going to offer a vehicle service contract part of the deal. So you outline the terms of a vehicle as it stands now, right? You outline the terms of vehicle service contract. You provide that document to the consumer, they have an opportunity to read it and they're signing. Right, I understand. And, and I've had an opportunity to read and this is not condition of financing all the sorts of things that go in there. They have, they have that you have a signed document that says I understand, I have a chance to read it, blah blah, blah. The c, the FTC news proposed rule says, guess what? That document that they sign voluntarily isn't enough by itself to establish express informed consent.

Well, what is.

So it's interesting, here's what they say. It has to be. And again, parsing this language is going to be interesting. It has to be an affirmative act communicating unambiguous assent to be charged. And it has to be made after receiving in close proximity to any disclosure in writing and also orally. So if a consumer was to challenge you. Well, I never provided express informed consent. And by the way, the FTC specifically says that like in the rule, that signed document isn't enough. Right. You can't have pre check boxes. That doesn't count as express informed consent. So customer comes in here and says, well I Never gave express informed consent on that. And you hold up the document and say, well, yeah, you did. You signed right here. Oh, no, I didn't give it orally. How are you going to prove?

I mean, you have to record everything.

Everything.

Yeah, I mean, it's going to be. There's so many issues that, that this rule presents, again, from a, from a cost perspective, the impact it's going to have on dealers and their compliance mechanisms, the impact it's going to have on the consumers. This is a fatally flawed document. Nada. If anybody's interested in the world listening to this, nada, put out a couple of little video vignettes that talk about the, the downsides to this rule and how this really was a ready, fire, aim kind of approach. It's, it's poor. It's just a poor effort. And here's what really makes it poor and interesting. I mentioned come back and tell you, well, who does it apply to? That it applies to motor vehicle dealers. But look at, listen to how they define motor vehicle dealers, which. And if you're familiar with the cfpb, Dodd Frank act, it talks about motor vehicle dealers being got to be licensed. Okay, well, everybody here is licensed curb stoners and may, you know, you know, again, that helps the curb stoning or.

Yeah, that doesn't apply to them yet.

But has to be licensed dealer that takes title to vehicles and is predominantly engaged in sale and servicing of motor vehicles or leasing and servicing of motor vehicles. Now, from an independent dealer perspective, how many independent dealers are not primarily engaged in servicing? It says both. Right. Sale and servicing, leasing and servicing. So if you're not engaged in servicing, well, then there's an argument this rule doesn't apply to you.

Oh, my goodness.

So here's the, here's the issue. If the FTC understood things, one, would we have a better rule that that is doable, but two, would it really cover the people that they intended? There's no way in my opinion, that they ever intended to exclude dealers that don't have servicing departments.

Another reason to have your service department separate from your dealership.

There you go. I mean, it's. Yeah, exactly. So interesting to kind of circle back to where Jeff's at right now and this idea of being in D.C. and talking about important issues. This is why you got to be in D.C. and talk about these sorts of things. Right? So that we don't have regulations, whether they're on the books now or proposed regulations that just missed the mark because look what's going to happen. Right? This is cfpb. And this is just me throwing things against the wall. Does the CFPB come back later and say, oh, well, the FTC only went so far. We have control over Buy here, pay here dealers. We're going to do something that's specific to buy here, pay here that's similar to this. Does the FTC come back and clean up some things? Yeah, who knows? All sorts of, all sorts of issues with that particular.

And that is the reason dealers out there listening, if you made it this far, that we have to stay involved and we have to give money to the pack, because these things are super important. And Sean, I know when, when you were heading up the pack, that was a big, big deal and we made a lot of great relationships and hopefully, hopefully by the end of this year, if we go back to Washington, we can really get our foot back in the door and, and see things the right way.

100. There's nothing more important than you having relationships with those that govern you. You know, we talk about it at, at the federal level and these are things that are happening in D.C. but it's happening in your state, it's happening in your municipality. You know, the one thing that I would encourage every one of you to do, right? And grassroots means grassroots. Start where you're at. Build relationships with your, with your local, whether it's your zoning director, whether it's your mayor, city council, all the above, right? Let them know who you are. Let them know what you do, who you employ, what your business is all about. Build those relationships. Because guess ultimately who become the congressman and congresswomen of the future.

It's.

It's that group, right? So if you're building relationships with them now, but, but I'd also say they also, they're the ones that are going to directly impact your lives in the moment. Right. Let them have an understanding of, of what it is that you do and why you do it and, and what you're about.

Sure. Well, Sean, we appreciate it. Jeff, you got anything to add?

While you're awesome. No, that's so great, Sean. Every time I learn and I get, I think I just, man, there are so many things I could be doing to make sure that I'm being proactive in my community and in those areas that matter. I probably can't, you know, do. I can do a little bit here in D.C. to help change and affect it, but locally, so much stuff could be done. So, Sean, we look forward to seeing you out in Vegas in a couple weeks.

Really excited about it. I hear payer United Summit is coming on strong. And for those of you that are, are interested and haven't signed up, there's still opportunity to do so.

It's, you know, two weeks from today. We'll be today. And we in class still have a.

Couple of cheap hotel rooms in the back pocket, so if you need something, reach out to Angela Snow and we'll, we'll get you hooked up.

Sounds great. Thank you, Sean.

Thanks, Sean.

Thanks for having me.

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