#70 -Advertising Law Complience with Micheal Goodman

Hello and welcome to this episode of the Independent Dealer Podcast. Today we have Michael Goodman of Hudson Cook. He is the go to guy for independent dealers and legal matters. We're going to talk legal today, right, Luke?

We are. And Michael has graciously given us his time to really educate us on a lot of the questions that have been asked lately, especially in the advertising front. The thing that you need to take out of this that Michael said that just, that's just amazing, is don't unpleasantly surprise your customer. And if you do that, Michael, I think we can keep it straight, right?

Yes, that's rule number one.

All right, here we go.

You are listening to the Independent Dealer Podcast with hosts Luke Godwin and Jeff Watson. Thank you so much for tuning in. Let's do this.

All right, Michael Goodman here. Thank you so much for your time. We really, really appreciate it. I know you're a busy man and just a wealth of knowledge, so we appreciate you joining here on the podcast. First off, Michael, give us just a little bit of background. What do you do there at Hudson Cook? What's your specialty and how did you get into it?

Sure. And thanks for having me. I spent my first five years as a lawyer at the Federal Trade Commission as a staff attorney there, and I investigated and brought cases involving consumer protection violations. After five years of bringing those cases, I left the FTC and joined Hudson Cook. And I've been here for over 14 years. And now I help my clients with compliance with the FTC standards and also the CFPB standards. And when my clients are being investigated by those agencies, I represent them in those investigations also. The best way to deal with me is on the compliance side rather than on the investigation side, but I handle both.

Let's stop real quick and introduce some people to Hudson Cook who don't know what Hudson Cook is. Hudson Cook is by far the.

Firm.

Who writes the book when it comes to car law in the United States. Pretty much everybody. Even though you think you don't deal with Hudson Cook, if you look at the bottom of your finance contract, I'd be willing to bet you it's been it says Hudson Cook down there. So Hudson Cook you deal with every day dealers who don't know who you are. Just a great set of attorneys or attorney firm that really keeps dealers, new cars and used car dealers compliant and they really help us in our day to day activities.

And an awesome friend of the Independent dealer.

For sure. For sure.

I support that.

Let me add that we've literally written a book called Car Law exactly, yeah.

So let me ask you this, Michael, to get into it, help us dealers that don't understand and maybe it's a little fuzzy over some advertising laws, places where you see this small independent lot getting in sticky situations. Maybe kind of your top few, like. Yeah, the faux pas that you see us stepping into all the time.

Sure. At the federal level, there are two standards that dealers really need to be thinking about. One is pretty vague and one is pretty specific. The vague standard is to prohibit deceptive acts and practices in advertising. So the standard is basically don't mislead people. And that can mean a million different things. And the more specific standard is Regulation Z which regulates credit advertising. And there are specific standards and do's and don'ts that come in the credit advertising context specifically.

So help us out then. Obviously deceptive advertising, that's a topic we could go down the road forever. And I do have a specific question on that. But help us just real quick. Reg Z is pretty cut and dry. What is that for dealers that don't know?

So there are a couple of basic standards in the Reg Z credit advertising provision. The first one is that the terms that you advertise have to be actually available to consumers who come to your lot. You cannot advertise terms that you're not willing to fulfill. On second, if you disclose a rate in your ad, it needs to be presented as an apr. And third, if you use what Regzi calls a triggering term in your advertising, that triggers an obligation to provide additional information so that consumers can do apples to apples comparisons by visiting different dealers. So the triggering terms are. The ones I see most often are the term of repayment, the amount of any payment, or if a down payment is required that triggers the obligation to provide additional information. And that additional information is the APR and the terms of repayment, which means you're telling people how many months they have to repay or how many bi weekly payments they're making and how much those payments are. Now for most creditors, there's not one specific set of terms that they would provide here because it depends on what car somebody buys, how much they put down and so on. And so Reg Z says you can give one or more representative examples and that can comply with Reg Z.

So these guys, so help me. I mean, Luke, I think, and I don't know if I should admit this on air, but forever, I had my down payments on my cars, you know. No, no, no, I take that back. I had my payments, so I had all my cars classified by X amount. X amount X amount.

You were a reg Z violator.

I was a reg Z violator for a minute because I did not have a disclosure. Right. If I'm going to put the payment or the down payment on the windshield, Right in that same windshield, I need to have those disclosures. The rest of the terms of the deal, right?

Yes. The standard applies to advertisements. And we could talk about whether a window sticker in a car on a lot is an advertisement, but it probably is.

Yeah.

Yeah, I would think so. It's okay, I can put 500 down, but underneath it I need to say 24 months, 20% interest rate. OAC.

Yeah, it's basically a one sentence disclosure that you need. You can pack everything you need into one statement. And it would say, example, if you pay $12,000 for this car and your rate is 12% APR, you would make 120 monthly payments of $200 and then you're done.

Cool, cool, cool, cool.

So make sure you're disclosing that. Now, that would apply for. If I'm one of those guys that posts my down payments online and I'm using Facebook Marketplace and saying 500 instead of the sales price, I'm putting the down payment as the sales price. That could A fall under deceptive, but B would definitely trigger any of those terms within the context of the ad, right?

It could. Again, this is if a down payment is required, that's the triggering term. And so if a down payment is optional, it's not the same.

Okay, Michael, we see. And Jeff just brought it up the with approved credit. Is that a triggering word? Is that a something we should as car dealers stay away from? What is your opinion on that kind of WAC or what'd you say? Oac, however you want to to describe that.

That's not a reg Z issue. It's not a required disclosure, it's not a prohibited claim, nothing like that. I see it all the time. And dealers use it to signal to consumers that the terms we're advertising aren't available to everybody. You have to qualify for them at the state level. There are states that don't want you to use abbreviations like that when they think that consumers don't know what they mean. I see OAC so frequently in the industry that it feels like it's a term that people could understand at this point. But you need to be aware of state standards that don't like it. And you need to make sure if you're using OAC that you have some reason to believe that consumers understand that means that I may not necessarily get these most favorable terms if my credit isn't great.

Mm.

And help me out. So along those. The lines of slogans and terms, is it legal for me to say, I know we got some CAC dealers that listen to this. Is it legal for me to say, everyone's approved? Does that seem deceptive? Guaranteed finance.

I like that smile there, Michael.

Well, I've had this conversation with clients before who say things like, everyone has approved or no one has turned down. The question I ask them is, is it true, and can you prove it if you're challenged? Lots of times the answer I get is, well, it depends, or, well, not everybody. And then that becomes a problem because then you've got a deception issue where your reality doesn't match your claim. And so the concept that you could look around and say, well, everybody does it. Everybody says everybody's approved. That's not a defense if the FTC or the CFPB starts asking questions about your advertising. And so you can only use an unconditional statement like that. Everyone is approved if you can back it up and show that it's true. And I think dealers will struggle with that.

Michael does it. So just on that same line of thinking, if I say everybody is approved, and. And you go, well, how about this person? You didn't approve them? I said, well, I told them they needed $10,000 down on a $11,000 car. Where are we there?

This gets into the gray area of deception compliance. And I get that explanation, too. Like, if the down payment's big enough, yeah, you'll get approved. But if your customer can't meet that requirement, and you kind of know how unlikely that is, that somebody who is that credit challenged isn't going to have $11,000 in their hand for a down payment, it becomes misleading at some point. There's no specific definition of where that is. But if you're relying on an explanation that none of your customers are satisfying, that can be deceptive also.

Yeah, that's the best I've ever heard right there.

Yeah, that's so smart. Because I think. I mean, I think of a company like Credit Acceptance. They're very large. I'm sure they've been challenged on their slogan, guarantee credit approval. But it is because of that everyone is approved, Mr. Customer. And here's the terms you're approved on. And so you're right. If it's always so extreme that no one, you know, meets that requirements, then, yeah, you're obviously being deceptive. I always tell my guys, I say, yes Everyone is approved on my terms, not on the terms they want. You know, a customer might come in and say, well, I want these terms. You said everyone's approved. Well, yeah, they are, but you don't get to pick the price, the interest rate, and the down payment.

I'm sorry, go ahead.

One way that I talk to clients to think about this is imagine you're advertising from the consumer's shoes, or maybe more importantly, from the regulator's shoes after they've received a consumer complaint. So the consumer goes into your dealership, has your ad, it says, everyone's approved. You said, yeah, we'll approve you if you can meet these impossible terms. So the consumer turns around and complains to the FTC and says their ad said everybody's approved. What they asked of me was impossible. So it seemed misleading because they just wanted to get me to show up by telling me I'd be approved, and then they were giving me terms I couldn't meet. That's what gives a regulator the foot in the door to open an investigation. Like, let's see what support you have for that claim.

I was going to ask you, what's the burden of proof? If that comes up, could you say, hey, well, I've had five people last year put down $10,000. I mean, is that a burden of proof? Or what would a dealer need to show?

That's a good question. The dealer does have the burden to show that their advertising is not deceptive. I mean, as a literal matter, the regulator would have a burden to show that you were deceptive at the end of the day. But the way these investigations unfold is, is basically the regulator going to the dealer and say, prove this wasn't deceptive. And that's when you need to give your support. One part of the deception standard under the federal law is that you need to have substantiation for claims that are objective or that can be measured. And so if you're advertising like pie in the sky terms, the regulator's gonna ask you, show me how many people receive those most favorable terms. And again, there's no threshold that you're trying to meet. But if you're down in the single digits, like, hardly anybody gets these most favorable terms that I'm advertising that can lay a foundation for a deception claim.

I see that so often with independent dealers in my town, Michael, where if you see their advertisement on TV or if you see their advertisement on the Internet, their advertising with 2.8%. Well, I've got Prime customers that don't get 2.8% nowadays. And I don't think those terms are available to consumers no matter what their credit is. How strictly is that enforced and is there something as dealers we can do to help enforce?

Well, that's a good question. I think it's fair to say that this is a target rich environment for the regulator and they can't go after every violation they see. And so they tend to hold their fire for when consumers have actually experienced economic harm. Or they may bundle together a series of investigations and try to get more bang for the buck. That way if they're advertising a rate that nobody gets, then you've got a deception problem and you've got a reg Z problem. Under that actually available standard.

Could we get.

But even if the dealer can, sorry.

Michael, could we get in trouble if we're a buy here pay here dealership that's advertising 0% interest and we say, hey, well we actually don't charge you interest here at this buy here pay here. Is that, I mean everyone's getting it, everyone's getting zero percent interest. But does that open up?

I think there's a whole nother, I think that's a whole nother path we can go down there.

Is that a different thing about payment packing or saying way, way, way. That's undisclosed finance charges. There's no way you're giving someone with poor credit a zero percent interest rate.

Well, the question the FTC is going to ask in that investigation is are you collecting interest by calling it some other thing or by some other name? So are you manipulating the prices of your vehicles in order to effectively charge that additional amount without calling it interest? And the FTC will consider that fair game in an enforcement action also.

Yeah, well, since Jeff opened up that door, that's one of my favorite doors. And I think it's just, in my opinion, it's a deceptive practice to advertise to a subprime customer that you're charging them 0% interest? Because I feel like it is being charged. Interest is being charged through the price of the car. Have you seen a challenge from government regulators on any of these 0% buy your payer stores or subprime lots.

From.

That perspective, saying, hold on, you're charging 200% of an ADA for your car? That can't happen. Have you seen anything there or can you speak on that?

I can't think of a case on those specific facts directly. It wouldn't surprise me if they're out there. I just don't think of one off the top of my Head. But the FTC for years has brought cases alleging that dealers have manipulated pricing and their advertising in order to draw people to the dealership. And they've been bringing cases like that for a long time and challenging that as deceptive. And this sounds like it would fit right into that legal theory from the FTC that if you're manipulating the pricing in your ads in order to get people to your dealership and not to the one down the street, that's deceptive.

So do you think there's any, I guess, CFPB issue there where if you're charging too much for your car, there's an interest, there's a hidden interest charge? I mean, do you think there's an issue there if you're charging double what your car should be worth?

I would definitely call that a risk of a law violation where if the FTC or the CFPB open an investigation, looks at your pricing, sees that you're charging double what your competitors are charging while you're advertising zero interest. I definitely see risk of a deception challenge with those facts.

So along with the deceptive advertising, this is something I wanted to get your opinion on, Michael. What I call the addendum epidemic. And it's really led on by the online pricing models of some of these websites that it's kind of the race to the bottom, right? You want to be a good deal in your region, you want to be the best price, you want to show up in the top of these lists. So what we're seeing is a lot of dealers that are pricing their cars extremely competitive, you know, at cost or below or super, super low as the sales price quote, unquote. And then when the customer shows up, all of a sudden you've got some nonsensical items tagged onto that price before you get out the door. And by nonsensical, I mean, you know, certified pre owned prices and pre delivery inspection fees and even recon fees and a shop fee and all these weird, weird fees at $900 doc fee. Not just your ancillary products like actual products, service contracts, gaps, those things I get those are, you know, f and I products that a customer opts in for hopefully. But these are, they're almost line iteming their costs of, you know, recon. I can't line item recon on my car, can I? So these customers are showing up, obviously they're being let in by a low price and then they're getting this actual out the door price. It's illegal, right? I mean black and white illegal or gray.

This is exactly what a bait and switch looks like, where you put.

Out.

An unreasonably low or deceptively low price to get people to show up. And then while you're at the dealership, all of a sudden the price of the vehicle starts to inflate as the additional fees are tacked on. That's an easy deception case for the FTC where you've. The FTC calls this a deceptive door opener, where you put out an advertisement with an unfairly low price to get this person to show up. And then when in the transaction, all of a sudden the price spikes as you tack on additional fees. This reminds me of an issue that I'm seeing in the hotel industry where hotels are advertising a low rate per night and then they're tacking on all these extra fees like a resort fee.

Or a parking fees.

Parking fee, exactly. I got hit with a parking fee and in Florida a couple times here lately.

Exactly. And a number of state attorneys general are looking into the hotel industry for these very same approaches to advertising. And the same thing happens in the dealer world also. This is classic bait and switch and the regulators don't like it.

Michael, correct me if I'm wrong, but in a new car type situation, addendums are legal, correct?

Well, when we get into dealer specific compliance, I don't want to speak to that here. I'd rather talk to somebody one on one to make sure I get my facts and respond to them.

Okay.

One thing I do want to talk about though, in this context, you mentioned this in online advertising. A lot of times dealers will have a hyperlink next to a vehicle price and the hyperlink provides additional information and additional fees that are tacked on. Hyperlinks can work in some contexts to explain things. I don't recommend that dealers use hyperlinks to explain or disclose additional fees that are tacked onto the price of the vehicle.

So I want to ask a couple more questions on that. What is legal as a line item? I know I can charge a reasonable dock fee, Right. And based on my state, I have to, you know, justify. Either my state will limit it or I have to be able to justify what actually goes into that doc fee or the cost of selling it. Are there other line items outside of F and I products, like can I charge a pre delivery inspection? If it's reasonable, can I charge a, you know, certified pre owned fee? Is that a thing?

Well, one thing I tell dealer clients is that one goal of compliance is to avoid unpleasant surprises for the consumer because consumers who are Unpleasantly surprised are consumers who complain to a regulator. And so the more you explain to consumers about how your pricing works and the more you provide information clearly and conspicuously, the better you're going to be at avoiding unpleasant surprises for consumers and avoiding consumer complaints. And so one general principle is however you structure your transactions, make sure consumers are getting the information clearly and at the time when they can make use of the information, not after they've already signed, started to sign the paperwork.

That's such a great thing to say. Don't unpleasantly surprise your customer with fees because, I mean, that's, that's where you get into trouble. That's the reason people get mad. If you unpleasantly, surprisingly repossess someone car, they may get mad too. So it's definitely a great philosophy to live by. I want to ask you one quick thing about dock fees. And I don't know if this is a nationwide thing or South Carolina thing. I'm in South Carolina. But we have to advertise our dock fee with the price of our car. Does FTC ever look at that or do they care about dock fees? Is that a federal. Is anything on the federal with that?

I've seen the CFPB be more aggressive than the FTC at treating state law violations as violations of federal law also. But the CFPB has certainly done that and said your state law violation is also an unfair or a deceptive act or practice that we can go after, too.

One other thing on the well, I know it's come up before, and I've had a friend that got in trouble with this is we will trade your car no matter how much you owe. Can you speak down that rabbit hole and kind of talk to dealers about that?

Well, the FTC has brought cases on those facts also, where you finance what you owe on your current car into the payment that you're making on the new car. And the FTC has gotten involved when that concept wasn't clear enough in the advertising that the amount you owe on your current car doesn't just go away, it gets financed into the new transaction. So what the FTC wants to see is a clear and conspicuous disclosure of what's actually happening in that transaction. Yeah, we'll take a trade on any vehicle, no matter what you owe. Here's how it works. The price of that loan is about to spike to accommodate what you owe on the car that you're trading in.

It's kind of hard to make that snappy, right? We'll trade your car no matter what you owe. But everything you owe over what it's worth is going to go into your new loan. I think that gets kind of slippery, doesn't it?

I totally agree. And that's one of the big challenges in the dealer advertising compliance work that I do is. And I tell clients, you don't want me to write your marketing for you, because sometimes they just say, tell me what I need to say and I'll say it. And I tell them, you don't want that because that's not what I'm good at. There's usually some back and forth between the dealer and outside counsel trying to get to a happy medium where the marketing people are satisfied and the compliance people are okay with it too.

That's awesome. Another question I see that happens at, at stores is I'm advertising a price on the Internet for, let's just use $10,000. But it's disclosed that I have to finance with the dealer to get that price because of course you know and I know that I'm getting a kickback from that finance company for doing that. So I'm making more on the car. Is that legal?

That's something that you address with a clear and conspicuous disclosure that if this price or these terms are contingent on you doing business with this finance company, you just need to say so in a way that consumers will understand and notice.

Okay.

That's one part of that means if you don't disclose that if you've got a block of fine print text and it's gray print on a white background and it goes for 30 lines at the bottom of an ad and you're disclosing this in line 18, that's not a good idea. Consumers need to be able to see the information and understand it.

You know, what I found is if you have a low price and you're marked as a good deal on these sides, you can put anything in those disclosures because nobody reads them. I try to spell out everything in the disclosures, and yet it's just constant questions of the same thing I already disclosed. So I don't. I know it's got to be there. Nobody reads it. All they see is that price and think they can come in and, you know, the new car stores want to give you some killer deal, but if you pay cash, it's actually not in their best interest. Like Luke said, you've got to finance with their captive bank.

It's a real challenge because dealers will look around and see what their competitors are doing and they're not getting in any trouble for it. And here's your outside counsel saying that's not a good idea and the dealer has a business risk decision to make. Is if your outside counsel is saying, don't do this, and your competitors are all doing it and not getting sued, the dealer is going to have to make a choice. I want to put in a plug for a resource that the FTC has that I use all the time. It's called the Dot Com Disclosure Guide, and it's a plain English discussion of providing good disclosures online. And I find it works for print, too. Just how to make things noticeable, how to satisfy the FTC that you've given consumers a fair shot to see what you're telling them.

Okay. And I'll try to put a link to that in the show notes so everyone can see it there. I'll find it on the site and link it there. Michael, so do you see, maybe as a word of caution or maybe just to kind of scare us straight, have you, have you seen some fines come down on small independent dealers? I always think to myself, like, I mean, I'd have to do some pretty egregious things to ever get on the radar of a federal agency or a state agency as a small independent dealer, but that can't be true. I mean, everyone's got an eyeball.

That's a great question. And an important thing for all dealers, especially the small ones, to keep in mind is if you draw the short straw and you're being investigated by the FTC or the CFPB for something that's common in your industry, it's going to cost you a lot of money to handle that investigation, even if the investigation doesn't go anywhere. Just the cost of responding to the FTC or the CFPB when they start asking for information can be very high. And it may be unlikely a small percentage of dealers get investigated. But like you say, the investigators, the regulators, they have eyes, too. And so they look at ads all the time, they're looking at consumer complaints all the time. They're looking for targets. It's easy for them to send out the investigation. It's very burdensome for the dealer to comply with it and just hoping that you don't draw the short straw. That's part of it, but another part of it is doing what you can to be compliant because that lessens the burden. You still have to deal with the cost of the investigation, but if the process stops there, you're a lot better off than if the FTC or the CFPB wants to bring an enforcement action against you.

Can you speak, Michael, and you may not be able to, but can you scare these people and just these other dealers out there and just kind of give an idea of what it may cost even if you're being investigated? If you have to bring in people to help you?

Sure. In my experience, the cost of the initial response to an investigation from a federal regulator starts in the mid five figures and goes up from there. And if there are follow on investigations, that adds to the cost. That can double the cost. If they send a second subpoena to you for more information, then there's the cost of negotiating a settlement with the regulator and then there's the financial penalty that they can impose on you to settle the case. So mid five figures is, I think, the very rock bottom starting point. If you get a subpoena from the CFPB or the FTC and you're going to quickly go up from there.

Wow, that would put a lot of independent dealers out of business real fast.

I think about that all the time because I want the FTC and the CFPB to know that they've been around long enough that I think they do know that, but they see that as cost of doing business. And something that just comes with being in a regulated industry is occasionally you're going to be asked to comply with a subpoena and that's going to be expensive. And that's, that's the world we live in.

Do they sometimes issue these subpoenas to shut people down? I mean, do you think that's a part of. If they really see that they're doing something that's really harming a consumer, would that be part of their reasoning behind doing it?

I wouldn't want dealers to think that the federal regulators are out there trying to close down businesses because that's not how they approach this job. They're looking for law violations and they want them to stop and they want to punish when necessary. But they're not out trying to put people out of business. The caveat to that is if they see a business that they think is rotten to the core or fraudulent to the core, where, and I don't see this in the dealer world compared to other places. But if you're just taking money from consumers and then not delivering what you've promised, then that can be a cost that's imposed on you. They can shut you down if it comes to it, but that's not how they approach the garden variety investigation.

Yeah. So let's ask this Michael to wrap this up you know, Luke and I, we definitely are of the philosophy and I know the people that listen to this podcast are the top percent of independent dealers. We care. We're trying to do it better. We want to know, we want to learn, we want to make sure we're in compliance. How do we police our own industry? Are there opportunities for us to say, hey, I know that there's these people doing it wrong and I actually had a customer come in and present me with the advertised price and their out the door price. And I have these two documents right here. What do we do with that? Do we send the customer to our state ag? Do we send them to the federal? Do we just have them make us stink about it online? Like, what is our responsibility as dealers to police our own industry?

Well, you can recommend those things. You can have the consumer submit a complaint to the state AG or to the federal complaint database. You can do it yourself. A lot of my clients are reluctant to turn in a competitor because they just don't want their name in front of the regulator at all. Even if it's as in the context of, I'm telling you about someone else, they just don't want their name on that information.

Email. Yeah.

I mean, so it's an option that's available. I think you'd probably get more traction from estate ag. I think they tend to be more active on sort of one off or small volume consumer complaints. Federal regulators get so many complaints that I think they look for a higher threshold before they investigate. State AGs tend to be more willing to open an investigation based on a.

Smaller volume as well as Department of Consumer Affairs. I'm on a council in South Carolina, Department of Consumer affairs. And we see, you know, not, not necessarily the car industry in it. But I'll tell you that the vast majority of the claims that go through Department of Consumer affairs in your state is car industry related. But there's some other businesses, funeral homes, it comes to my mind really quickly as just a rotten industry. I mean, in general and pawn business and things like this. But there's really good resources there to help, help combat these things too. Yeah.

So encourage the customer, the consumer to file the complaint. I think we need to do that because it gives everyone a bad name, you know what I'm saying? Obviously, used car dealers were fighting it from the beginning to try to convince people that we're not sketchy or schemy or skizzy. And then these guys down the street are doing this deceptive advertising. Turn them into the ag, turn them into Your Motor Vehicle Enforcement division. Get that consumer to file that complaint. That's the only way we're going to change it now. Michael, we've taken way too much of your time. I really appreciate it. How can people get a hold of you or your firm if they want to learn more, if they want to make sure they're in compliance? I'm sure you have a level of services that you provide to independent dealers where you would audit their documents or their advertising or give them counsel. How can we make contact with you?

Hudson Cook works with dealers all day, every day. Our website's probably the easiest way to get people connected with us. Hudsoncook.com and I'm happy if anyone wants to email me directly@mgoodmanudcode.com those are the two easiest ways. And we're happy to talk to anybody who wants to talk to us.

That's great. If you haven't seen Tom speak and others within the firm speak at a convention. Next time you're at a convention, go sit in there, listen and take notes. Because he will explain everything you probably need to know. Not everything, but a lot of it. And he really, really has worked hard in our industry to keep us educated and to try to get us to do things the right way.

I totally agree, Michael.

Thank you.

Michael, thank you very much.

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