#309 - CARS Rule And What It Means For Dealers

This is the Independent Dealer Podcast, Education by Dealers for Dealers. Now here are your hosts, Luke Godwin and Jeff Watson.

Hello and welcome to the Independent Dealer Podcast, brought to you by Buckeye Dealership Consulting. Luke, I'm going to be straight with you, man. I have no idea why these two gentlemen are here. I don't know what's going on.

It's always, it's always trouble when you have two attorneys that focus on the car business on our show. This is not, this is not a good sign.

So I googled something about the topic of this podcast, the FTC cars rule. And if you guys are like the average dealer myself, you've seen a little bit every so often. You catch Steve's post, you catch Sean's posts about this cars rule. It stands for combating Auto Retail Scams. Now, like, if that doesn't set you up for success, I don't know, I don't know what kind of rule does. Guys rule. Welcome to the podcast. What do we have going on here? And the federal government has just set up a brand new rule to keep us from scamming people.

And let's, let's set up our guests as well. Sean Peterson with Buckeye Dealership Consulting and Steve Levine with Steve. I forget the name, but everybody knows who Steve Levine is.

Ignite.

Ignite. That's right. Sorry. And, and there are two attorneys. I mean, need we say more? And they specialize.

One isn't enough.

Yeah, I think, Luke, the old joke goes, you know what, what do you call one attorney at the bottom of the sea?

A good start. Yeah.

So I mean, that's just.

What do you call two attorneys on the independent neighbor podcast? Trouble. That's, that's what we're gonna. So. And I think the FTC car rules probably requires at least two attorneys to try to make any sense of this. So let's, let's talk about why this apparently is needed from the SC FTC's perspective. I don't think it's needed, but there are some bad actors in our, in our business, Jeff, and I think there's bad actors all over the board. Sean, would you like to say why the FTC thinks this is needed?

Well, I, that's the, the probably $60 million question, not $60,000 question. Nobody, nobody can answer that from the industry perspective. Right. The, the why doesn't make a lot of sense because most of the, the acts and practices that they're looking to prohibit, they're already prohibited. They're already regulated.

Exactly.

But they're not enforced.

Yeah.

Well, there's certainly some argument that people, consumer advocates would make that, that, that they're not enforced. I think the industry would obviously disagree with that too. But, but if you look at the course of the last, let's say dozen years really since the CFPB came into creation in 2010 and, and the existence of this Dodd Frank statute, there have been multiple opportunities for the, the FTC to, to engage in a legitimate research, well evidenced and, and rational rulemaking process. And they've punted every time. From an enforcement standpoint, they have pursued some cases to be sure. But if you look at the scope of those cases over the course of the last 10, 10 years or so, there's only been about 35, 37, something like that, but it's been less than 40 that are actually against the dealers for what I might say would be alleged, you know, misconduct that nobody wants in the business. Certainly. You know, I, I think everybody would.

Tell us what is this? I, I think we need to go to the beginning because like me and most dealers, I don't even know what this is. What are they doing, what are they trying to get at us? And what do we dealers need to know to stop doing?

So yeah, there's a saying, you learn this in law school. Bad facts make bad law. So they went and interviewed a bunch of really ticked off consumers, found some very egregious examples and basically built a very cumbersome rule around those horrible experiences that people had. And I don't think I'm overstating that because they say it itself.

And what's interesting Steve, real quick is the number of people that they interviewed was 38. Yeah, all, all from one market. Right. Some dealers, Greater D.C. that's it. That's it.

Some senator's son got screwed or, or pissed off or their uncle got taken advantage of and now it becomes a federal law. So what is it Steve?

So, so yeah, yeah, just in summary, there's basically four pillars to it. It's going to prohibit misrepresentation about material information. You know, the, the key information in transaction. It's going to require dealers to disclose what's called the offering price, the actual price anyone can pay to, to buy a car, finance a car, excluding only required government charges. You know, so, so things like, like non mandated DOC fees and, and other fees that get packed on that, that's going to be part of the offering price. Number three is it makes it illegal for dealers to charge consumers for add ons that don't provide a benefit which you know, I Could argue that that's already illegal, but, but they're codifying it here. And, and finally they're requiring dealers to, to get express informed consent before charging consumers anything. So.

So, I mean, that's what we do already, right?

Well, yeah, that's what good dealers do. I mean, granted, I've got some energy about this rule because I really think that they overshot. Yes, there are bad deals out there, and I look at a lot of deals and there's a wide range of disclosures and paperwork, but I think a lot of this is already illegal under various laws. FTC just wanted to clarify and codify that. It's interesting to me. FTC seem to be wrapping themselves up and they say this a lot of times that they issued a dealer's guide, kind of informing dealers on what they need to look at. Everybody go to ftc.gov and pull the dealer's guide. And they keep on getting back to the fact that there are bad dealers out there and honest dealers are being hurt and all. Salesman could tell you stories about how they lost a deal to somebody crosstown that wasn't following the rules. It just seems to me that they're really trying to wrap themselves up. And, you know, honest dealers should love this rule because it's a good thing. And, you know, they go so far as to say, well, this isn't going to add any, any time. It's not going to add any paperwork. And boy, I've got a lot to say about that because I, I think it's going to.

Yeah. You know, I think one of the biggest, the biggest issues that I see happening in the used car market is false advertising pricing. And, and there's already rules in effect that aren't enforced when it comes to false advertising. I could get on car Gurus. I could get on Auto Trader. I could get on cars.com I get on Facebook Marketplace right now, pull up a car that I, I see is a good deal. I could go to that dealership and I'm telling you, probably nine times out of 10, I'm not going to be able to buy it for the price that's advertised. I have friends all around that, that run into this problem and they say, look, what am I supposed to do? I said, well, I wouldn't do business with a dealer that's, that's not, you know, not living up to the law in the spirit of the law. And, and there's been times in South Carolina where this has been challenged by, by Department of Consumer affairs to no avail. If anything Needs to be done. This already needs to be enforced, but it hasn't been. And it's a definite right now it's an FTC rule violation. How's this going to change it?

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Well, you know, I, I think that they're, they're making it very clear that this is the, the standard we're holding the industry to. And, and some of those bad examples I talked about earlier, you know, they, they talked about one case where, where somebody called and got a price, and they drove three hours to go to the dealership, and it was several thousand dollars more expensive because all this dealer pack. Yep, I get that. I do think that needs to stop. But I also want to bet that that jurisdiction already has a deceptive acts and practices statute that should stop that if it was enforced. And if that consumer went to a lawyer or called the state regulator, there's already plenty of meat to enforce that. So I don't know that we needed this, but, you know, I spent the first month resisting it, and now I'm kind of like, well, this is what we have to live with. So what's the best way to get folks to as painlessly as possible, comply?

So let me jump in on that, Luke, because I think it's a really good question. Right. Agree with Steve 100%. Right. These false advertiser, they're already regulated, right? There's laws in place that prevent that. Why would the FTC do this? Going back to the first question, and, and, and, and what's different, this new rule just gives Them an easier way to do it.

Right.

When, when the, the existing stuff talks about, you know, unfair, deceptive, related things. And some of the state regulations will have specifics as it pertains, pertains to advertising. Thou shalt not do this and thou shalt do that. We get it right. Truth and lending has those sorts of things as well. When you're, when you're advertising cost of credit, these, this, this cars rule has now some very specific things that you have to do.

Right.

Check boxes and we'll certainly can get into some of that. It makes it easier to enforce. If you don't check the box, it's easier for me to show up and say all right now you owe me X number of dollars and we're going to take you to court and we're going to enter to some administrat of consent decree. It just makes it easier for them. But it's already regulated.

Okay. Yeah, so it was, that was, it.

Was, it was regulated. Then why did it persist for so long? Right. So you say the deceptive pricing game, Luke. It is illegal, but yet all the new car stores do it and some of the used car stores. Right. They all play the game and they've played it for so long it obviously is not enforced.

No, it's not.

But they all do it. So you know, stop that from happening.

I've had several people take in South Carolina. There was a big lawsuit years ago about, about closing fees and several large dealer franchise groups got, got nailed pretty good. Right. And then they make a rule and then everybody breaks the rule again. They don't advertise in their fees and everything. Like we've taken number of franchise stores because this, I think a lot of these things go on in franchise stores. Taking them to the department of consumer affairs who does that, regulates that in South Carolina and laid it in front of them. And you know what they did? These new car stores told them to go pound sand. They didn't care and they have the political backing to do it. So hopefully this could help with that because there's the state level. Sometimes it just can't get done. I'm not for this, but I think if they can do anything to help, this would go a long way in our industry.

I actually agree with that part of it. I think there is a problem that offering price hopefully is going to solve because I think there's a lot of misleading information put out there. So to that extent I do think it's good. Again, I think the FTC trying to wrap itself as the good guys. And we want to help honest dealers. I think that's a little disingenuous. They're clearly a consumer protection arm. But I do think that part of it is fair. I think going after some of the add on products that folks either aren't being told or voluntary. They're mandated. I don't mind that either, you know, but, but, but I, I think some of this other stuff where they're basically coming up with a laundry list based on again, the, the worst examples that you could find.

Can you, can you, can you give it an example of what some dealers out there are, are charging for that, that don't give any benefit to a customer that they're talking about?

In number three, I'll give you a perfect example. So I actually had a good friend of mine call me and say, hey, I'm standing at the lot with my daughter. We're going to buy a car. The guy's trying to sell me a Gap product. And she told me I've got about $10,000 in cash to put down. Like, you don't need a Gap product, right? Yeah, they're trying to shove it down their face, you know, and I told her to push back. So that would, it would be something like that where there's clearly no benefit that the consumer is going to derive from, from having that product.

Yeah. Selling you a powertrain warranty when the car's still got powertrain warranty left. Factory warranty. Right.

But, but you know, I want to address something that Sean said because, Sean, I found this interesting. I, I totally agree about that Gap example, but you know, then they start talking about loan to value ratios and making sure that it makes sense from the consumer standpoint. But they don't give you any sort of hard line number as a safe harbor. You know, I kind of scratch my head. I don't know what the right number is. I don't know when you reach it.

So. Yeah, that's a great, that's a great point, Steve. If I have a customer that comes in and puts $5,000 down on a $20,000 car and I sell them Gap, am I triggered then?

You know, personally, I wouldn't.

We don't know. We don't know.

Yeah, we don't know.

Because if I don't sell the customer gap and they wreck it tomorrow and there is a gap, then is the consumer, are they able to come back at me?

Yeah, yeah. And then, and then you have the other point. For years my advice has been offer everything, everything to everybody, offer Everybody the same thing. So you. You can't, you know, boomerang back and be said to be discriminating.

Yeah, we have a rule 100 of product, 100 of the time.

Yeah, I could see that being a benefit to some dealers. Right. It's going to train their F and I guy to go down the entire laundry list of items that he's trying to get sold and push them all, you know, so you can get a yes or no from each one.

Yeah, yeah, they're gonna have to.

So in Utah, we had a recent law passed that went into effect this year that one legislator, my legislator, close buddy, daughter, went to a car lot and felt like she didn't understand the sales agreement. So he implemented what's called a statement of understanding. So now in the state of Utah, we have a separate document that is a statement of understanding, which is basically just a regurgitation of the contract.

Right.

What did you buy it for? What did you get for trade? What were the side products? What did you pay in tax? It's like everything's in these documents already. You just have these people that come out and say, well, let's just. Let's make it purple instead of blue. Let's put a box around it so that people can understand the boxes better. Like, it's all there.

Well, that's what. That's another document. That's what number four sounds like. Requires dealers to get consumers express informed consent before charging them for anything. And Steve, the last time we had you on here, I'm pretty sure we talked about junk fees, and I assume that's where this comes. Have we been able to define what a junk fee is yet?

Not to my satisfaction. Because, you know, if you look at the FTC and both the CFPB as well, anything that leads to any sort of profit to. To a dealer that they seem to want to call it a junk fee.

There's actually a proposed rule that the FTC has that they're soliciting comments on right now about junk fees and how that'll be defined. And I mean, in and of itself could be problematic. So.

So, Luke, we switched our payment processor, or we're in the process of processing our payment processor over to Blitzpay. Right. I did a research. I looked at all of them. You guys have heard that episode. I am so surprised by the amount of customers who are just like, positive feedback. They're like, it was so easy to set up my portal. It's so easy to make a payment. It's just easy. Right. We've had zero pushback.

It's really, really an easy setup, easy platform. I think Blitzpay reached out to us when we switched back in March. Like, how did y' all get so much buy in so quickly to people using this? And it really wasn't us, it was their product. So save yourself some money, save your customers some aggravation, switch to Blitzpay and start collecting better and processing payments better. So we talked about it here. The next question I have, I have two questions here. How much more is this going to cost me per deal? I mean, you know, that's one of those things. This is going to be a cost for sure. And I've already taken a hit over the last two years. My gross margins have shrunken because of, because of everything else going on. When does this go, in effect? How much is it going to cost me and where. How do I get trained to even figure all this out?

So great questions, all of them. Let me, let me kind of give you a little bit of, you know, process of what's going on right now. So the cost is largely an unknown thing. And that's actually one of the arguments that the nada, the franchise association and their Texas affiliate have raised in a petition that they have filed with the Fifth Circuit Court of Appeals here in Texas. Right. So they're challenging the FTC's rule. They filed a brief. FTC has a chance to respond here within the next couple days. But they're asking the court to toss the rule for a bunch of different reasons, one of which is they haven't clearly defined exactly that question.

Right.

How much is this going to cost? Like, they've, they've put in a. Just kind of general amorphous. Well, of course there'll be some compliance costs, but it's, it's the juice is worth the squeeze, in essence, is what the FTC is saying. But they have to demonstrate that there's, you know, what that, you know, cost and benefit analysis is. And the NADA is arguing that they have done that. That will be an interesting argument. They've raised other arguments like the FTC didn't follow their own rulemaking process when issuing this, that there's no evidence, you know, Steve mentioned this, you know, these interviews. 38 people. Well, well, that's. There's no quantitative ev. Like specific hardcore evidence that you can point to no research. But they also point to the fact that, that the legal term is arbitrary and capricious. Right. In essence, it's just pulling something out of your rear end and throwing against the wall type of an argument. But what they're saying there is, you know, the f. The FTC is, is putting this out there without understanding what the impact is on the industry. And then they, they, they in essence in this, in this final rule said we, we don't think the, the impact will be any different for the in person closing as opposed to an in person shopping as opposed to online shopping. Well, based off of what? Right. That's just a random conclusion that they, that they made. I'll be very interesting to see how the court handles this case. Interestingly enough, this court is the same court that heard the case that found the CFPB and their funding mechanism to be unconstitutional. That case is now the Supreme Court. Right. This is the same court that started that.

Yeah.

Process. So they're asking for the court to kick the rule. In the meantime, they're asking for a stay because dealers will need to start ramping up. Right.

The rule.

If, if everything stays at the status quo, the, the rule takes effect at the end of July and dealers will have to be in compliance with provision by that point in time.

That's impossible.

About that. Yeah, let's talk about that for a second because to me that, that was, that was very political. They obviously want to get this implemented before the election. So they gave the industry very short Runway. I mean they looked this thing for almost a year and a half and then they announced it in December, you know, right. In time for the holidays. The industry is kicking up for, for tax season. And then you're supposed to have this implemented. I mean it's a ridiculously short time frame.

And think about, so think about some of the things to, to your other question. You know, what do I need to do?

Right.

There will be forms changes, there's going to be technology changes, there's going to be training that's going to need to. Because the entire process is going to be different. Right. Changes that you need to make to websites and engaging customers and all this. It, to me, it's hard to quantify a specific number, but it sure sounds like it's cha ching, cha ching cha ching pretty quickly.

And I thought it was laughable that they, they said well this isn't going to add any more time and it's not going to documentation. I mean, because all I'm thinking of, how are you going to prove that you've done all this? It's going to be documentation. And then we haven't spoken about record retention yet. There's a record retention component to all of this too, where just about everything the dealer does, whether it's a closed transaction or not, has to be retained for at least 24 months. So that's another component that dealers are going to have to worry about.

I mean, we keep all our records for a long time. What kills me is it says your ads. So all of your ads have to be retained for 24 months. So if you post a posting to Facebook with a price in it, you would have to sometimes somehow archive that ad for 24 months so that you can someday in the future prove that you didn't post an illegal price.

I'll give you another one that'll blow your mind. Right. Because there's arguments out there. What if you have a telephone message on your, you know, in your ivr before you, somebody picks up the phone and you're running whatever verbally that could be construed to be an ad that you're going to have to keep some record of that even this.

Require dealers to put their dock fee in the advertised price.

We have to do that. And we have to do that already, Jeff.

You do. We don't. And a lot of dealers get away with these insane dock fees because they don't have to put it in the advertised price.

That's now the offering price.

Yeah, that's now the offering price. Right. Because it's not a federal or a state mandated fee. Any of those. That would include obviously the market based adjustments. Right. And I think that's really where this door got opened is all those dealers who were putting in market based adjustments. And I said it at the time, this is going to be the catalyst for them to come after us. Because dealers got so greedy with the market based adjustments and not putting it.

In the advertised price and people not putting recon in advertising prices, which we've seen. Transport, transportation, all these things. Yeah. And they're not advertising.

I'm going to charge you for everything after the fact. Like I'm Southwest Airlines, like.

Yeah, I just, I don't see how we could even begin to be ready in July for this. What are, with that being said, what are the chances this is. If, if the court works or not works, what are the chances that it actually will go into effect in July?

Well, if you want me to handicap it, I mean, look, it's, it's pretty evident that there was a, a concerted effort to find an opportunity to put this case in this court. Right.

It.

Because this court has a history of, you know, pumping the brakes on government action, AKA what happen with the cfpb so if you, if you want me to handicap it, I'd say it's a better than average shot that there will be a stay that's granted.

Right.

Good. Part, part of the idea of, of a court giving a stay is that absent the stay, there would be irreparable harm. So while they're arguing the actual outcome of the rule itself, right. If, if, if dealers have to ramp up with compliance costs that could be significant and are largely undefined at this point in significant, that would be a, you know, it's a cost that they would never be able to recoup. So I think there's a better than average chance that a court would grant the stay. Now, with respect to the ultimate outcome, I, I don't know that. I mean, that one's a much harder argument, I think, to, to handicap while they're, while they're debating the, the merits of the rule itself and whether it, it was actually done properly and, and all the sorts of arguments that that NAD is reaching. So I interested. I don't want to share people. I don't want to scare people off or, or maybe even. I don't want to suggest necessarily that this is something that they can just close their eyes on and not start to get ready for. I think, I think dealers need to move forward with the idea that July 31st is coming or 30th. I remember 30, 31st, but I think they need to prepare for that. The court, my guess, is not going to, to issue any kind of ruling. Nada asked for a ruling by, on the stay by March 31st. So we'll see if the court's able to do that or not.

But let me propose this to you guys that are listening. April 23rd, we are going to be having Buy Here Pay Here United in Las Vegas at the Bellagio. If you come to that, I guarantee you Sean and Steve will give us a much better update of where this thing will sit and, and what we are going to need to be prepared for ultimately. Right. I mean, come the end of April, we're going to know whether we've got to stay or whether we need to be scrambling the jets and getting this out. Right, guys? I imagine it Buy Here Pay Here United. Do we have some education sessions planned on this? You all know, guys, Buckeye Reinsurance Products. I have also made the switch, you know, making the switch to all of our vendors. I guess I don't know which came first, but I'm switching my stuff over to Buckeye right now. It's a process, you know, but we're getting it set up so that we could be better at selling those products. Right. I'm reinventing the products, I'm repricing them, I'm looking at all of our back end stuff again and figuring out how I can use that reinsurance company to set up long term wealth.

Yeah, and we always talk about that long term wealth. The best time to get started with Buckeye is today. Call them, get set up, they'll have you going. You can get all that tax, tax money into your reinsurance company and start, start booking it, man. That's what you got to do. Give them a call today.

Yes, we do. I'm going to be leading a class on this the very first day, Wednesday morning, I believe. And joining me because I thought this was really important, joining me are going to be two representatives of service providers because I don't think this is being talked about enough. You know, I used to work for a DMS and I could just flat out tell you we weren't staffed to get a couple of hundred requests to change a document all at once. And I think that's a big part of that. So I plan to talk to those service providers and kind of ask them, what are you doing to be able to meet what's going to be an avalanche of demand?

Yeah.

How great would it be if they just had these documents pre programmed for us and we can.

Well, they should, I think.

Yeah.

So with the other thing, I'll add real quick, Jeff, and this is a conversation you and I have had multiple times. Right. The one thing that Steve is going to do in this session as well, those that come, they're going to walk out of there with a checklist. Here's what you need to do. Check the boxes.

Yep, love, I love me a good checklist, that's for sure. Tell me, give it to me in just straightforward English and let me check the boxes. This whole friggin news release that they put out is nonsense. I need Steve to interpret it and give me the actual.

Let me, let me share this because I thought this was interesting. So you know, we do webinars every month at Ignite. We did one in December, right when this came out and then we did one yesterday and we had more questions than we've ever had on a webinar before. And it was really hard for us to give blanket answers because the people on the webinars, we work with, a lot of them, we know their situation and the answer isn't the same depending on their size. Model everything else. So basically I spent the afternoon after the webinar reaching out to people one on one. Sorry that wasn't more clear but you know, your situation's a little bit different than the weather question. So I think there's a lot of it too. So, so yeah, my goal in, in putting that, that material together, if I hear Payer United is to at least give people a fighting chance to walk away with something that they could take back and say, okay, this is what we have to execute and this is our timeline.

Yeah, Steve, I think you picking out some of those best questions and answers and, and putting that out to the people at the buy here pay here summit would be also helpful because some of us don't know what to ask.

Right.

We're just kind of like who knows? But I know Buy her Pay here United Summit's going to be great. Sean, what else can we look forward to?

Well, we've got a fantastic agenda. It's up on the website. Everybody wants to go. Check it out@bhphunited.com you can register there, book your room there. We've got fantastic classes and underwriting and collections. We've got service inventory recon. We're going to have a discussion from, from a couple of dealers on, on how they've kind of navigated the, the, the ever changing marketplace, what, what they've done with you know, cost of capital increases and how they've handled inventory concerns, how they weather the storm and what they anticipate, you know, life looking like over the course of the next little bit as well. We've got great speakers like Brent Carmichael and David Brotherton obviously Steve. But most importantly we've got dealers that are, that are doing some stuff. But one of the, one of the highlights everybody in, in independent dealer podcast world is our dealer open forum sessions that are going to be moderated by. Yeah, so we're, we're really excited about that.

Jeff. I signed us up for that. We're gonna, we're gonna provide the wrap up every afternoon.

Ah.

He'Ll be up for it. He doesn't live too far away.

This, this might be a little like, kind of like a marriage where maybe they don't always communicate real well.

We don't have a shared calendar. We should have a shared calendar. Put these things on here. You commit me to these things. No, but, but I like that idea because I always think at the end of the day, yes, I do have a whole list of action items and take homes and things that I even just want clarification on like, hey, this sparked my brain to maybe implement this. Maybe I could pull the room of a bunch of dealers and say, hey, when you guys heard Steve talk, what did you think about this thing? Has anyone done it? Have you not done it? Is that kind of what that's going to be, Luke?

I think so. And, and this is something that is very. The last two Buy Here, Pay Her United summits has done this. The very end of the day, you just kind of bring everything together, bring everybody in the same room. We're on stage, we're going to be taking questions, we're going to be answering questions. If we don't have the answer, we'll pull somebody out of the audience that does have that answer. And so, yeah, we're just going to do a wrap up because I really think that's during the day at these conventions you get so much put into your brain. Maybe you took a note that you didn't understand, maybe you didn't understand an acronym that somebody used that, that you need to go down that path. Right. And we're going to be there to help help navigate that and help take all that garbage, the glue or whatever it is inside your brain and, and kind of put it in file cabinets. Because sometimes it's hard for us to get those file cabinets going. And you know, it's gonna be fun. April 23, which is a Tuesday, there's a, there's a reception that night. Wednesday, Thursday is the summit. And we're at the Bellagio again, correct?

Yes, sir.

Registrations open. It's a great deal. It's been so much fun the last two years. We can't wait to be back this year, guys. We really appreciate y' all letting us be involved.

And it looks like we're gonna have some Spanish specific tracks too, right. In all Spanish presentations.

So here. And resounding success. And, and everybody is excited about that. The, the Spanish speaking dealers that we've heard from are really excited about that again and we expect that to really grow. And that'll be. Most of those sessions will be dealer led.

Yeah. And that helps to bring your managers, your sales managers, even your salesmen that are just specifically Spanish speaking or feel more comfortable with it and think they might be out of place. But this gives them that opportunity to hear it all in, you know, the nuances to the words and the language in the presentation are a little bit different. So that helps so much. Instead of trying to translate it yourself.

I can't wait. I'm going to get in trouble with my wife. Because her birthday is on the 25th. I've asked her to come out.

She.

She has declined. So, Jeff, just you and me, but good.

You take me out for a nice dinner then.

Oh, yeah, you know I will.

Sean, Steve, guys, thank you so much for your time. This has been super informative. We definitely look forward to buy here Pay here United April 23rd. Appreciate your time.

Thanks, guys.

Thank you, guys. This has been great.

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