The Consumer Financial Protection Bureau (CFPB) recently issued its Winter 2015 Supervisory Highlights report. In it, the bureau noted that compliance programs at some entities were failing due to a lack of ownership involvement in compliance programs.

This point cannot be overstressed: Ownership involvement in the dealership compliance program is required, not a suggestion. Well-planned dealership compliance programs will prevent and reduce regulatory violations. Basic components of a program include include:

• Written compliance policies and procedures.
• Training.
• Compliance monitoring and corrective action.

To establish policies and procedures in your dealership, an assessment must be done to determine compliance needs, risks, and training issues—mostly pertaining to information privacy and security, F&I regulations, and employee safety.

Policies and Procedures Objectives

Policies and procedures should be written, and cover compliance risks disclosed through assessments. These policies should:

• Identify compliance requirements and individual responsibility.
• Convey dealership policy and expectations.
• Provide consequences for failing to comply.

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