Manson spoke about compliance last week with Automotive News Special Correspondent Jim Henry.
You've said big dealership groups are targets for the CFPB and FTC. Why?
I feel they're always looking at the opportunity of going after us in a way that maybe they wouldn't in the case of a mom-and-pop store in a small market. We try to be way ahead of the game so if they walked in here today, we can be confident they're not going to find anything wrong.
We're No. 1 in the Kansas City area in terms of Chevrolet. Between two stores, we have a market share of over 30 percent in the Kansas City market. We are definitely a target for the Feds based on our volume.
What do you do in terms of security that's unusual?
We have secure areas -- documentation areas -- where nobody can come in there without a passkey, a card reader. It's time-stamped and keeps track of who enters and who exits.
We are always checking our deals for menu sign-offs that show the customer knew what they were buying and what they didn't buy and that all the paperwork is present and done completely. Not only that, we have a third-party vendor who checks our checker.
Does the outside checker look at every single deal?
We have an outside vendor who comes in and randomly pulls around 10 forms for each producer each month. They don't look at every single one. They're making sure the menus are done and signed off; that there are copies of things that are required up front, like the driver's license; and that final declinations [declines to purchase] have been signed off.
Does your internal double-checking take place while the customer is still there?
No. But while the customer is still there we do kick in the name and Social Security number and address into the software program we use. Then we ask them questions that only that person could answer, like out of the last five addresses where you've lived, which one of these is true?
You do this for everybody, not just for customers who raise a red flag because, for example, the middle initial is wrong?
We do it for 100 percent of our clients. The questions are like: "Out of all these Zip codes, which one did you live in?" It may be none of them. "Where were your parents born?" Things like that.
Software programs enable dealerships to choose the level of security check it wants performed on customers -- low, medium or high. Your settings are at the high end, right?
Why are you so strict? Have you been burned in the past?
I'm proud to say I've never been burnt in the past, and I've got 20 years with this dealer group. Everything is aboveboard and transparent. I'm going to protect my dealer and our customers' information. That is my job -- to make sure we're protected.
Do the compliance programs apply to other departments, too, not just F&I? It seems like they must.
The whole store -- not just F&I, but the service department, the body shop, each one has a compliance program. When the guys are detailing a car we took in trade, if they find any customer information in the glove box, we have to shred it. Our vendor even goes through our trash to make sure they're shredding everything they're supposed to be shredding. We have shredders throughout the dealership. If our guy from the outside finds something in the trash that should've been shredded, they bring it to our attention.
You must do a lot of training.
One of the things I take pride in is education. All our managers -- the office managers to the desk managers -- all the F&I personnel, any directors are all certified by the Association of Finance & Insurance Professionals to the Masters level.
We are aware of what is correct and incorrect. Our main goal is CSI, customer satisfaction. We want their repeat business.