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A COMPLIANCE QUIZ FOR 2021
BY CHARAPP & WEISS, LLP
This quiz tests your knowledge on the sta- True or False? Under the Truth in True or False? We want to run credit
tus of some critical compliance issues for Lending Act, if we advertise a low bureau reports on employment can-
your dealership. 4 APR, we must also disclose the 9 didates to make sure they don’t have
amount or percentage of the down pay- credit problems. Our employment appli-
True or False? Arbitration agreements ment, and the terms of repayment. cation contains an authorization to run a
are regularly challenged by plaintiffs’ credit report on an employment applicant,
1attorneys. But there are substantial True or False? We have some especial- but we cannot do so based simply on the
benefits to arbitration – reduced time to ly low lease rates. Even though those signature on an employment application.
r
a
a decision, removal of the possibility of a 5 e like the annual percentage rate, we
runaway jury, limited discovery, to name a cannot advertise those as low APR leases. Choose the Correct Answer.
few. We can still use arbitration agreements What should be covered in a
s
for transactions with customers and for True or False? We spot delivered a ve- 10 lesperson’s pay plan?
a
employees. hicle to a difficult customer for whom A. The length of the salesperson’s employ-
6 e cannot find a finance source to ap- ment
w
True or False? We stopped using the prove assignment of the RISC. The custom- B. The specific definition of vehicle cost
NADA Fair Lending program when er is finally agreeing to return the vehicle. C. All pay calculations are final
C
2 ongress stopped the CFPB assault on Because of the extra work we had to do, we D. None of the above
dealer reserve. We still train our sales and wish to keep the downpayment. We may do E. All of the above
F&I employees that finance rates should be so if we can justify our expenses.
provided to customers on a nondiscrimina- True or False? An employee filed
tory basis. Our fair lending training should True or False? We spot delivered a car, a claim of harassment. We didn’t
v
protect us from lawsuits. and we cannot find a finance source to 11 iolate federal law by harassing
7 accept the RISC. We also cannot find the employee in the first place, so we can’t
True or False? When we advertise an the customer or the car to repossess it de- be found liable for taking action against the
attractive APR, we must disclose any spite diligent efforts to locate them. We can employee for filing a complaint.
3 alifiers such as the limit on the report the vehicle as stolen.
q
u
duration of the financing, and we must True or False? Salespeople are
disclose the amount or percentage of the True or False? An employee handbook paid on commission. They don’t
downpayment and the terms of repayment. is dangerous because it lets employees 12 ve to punch the time clock.
a
h
k
8 ow what their rights are. Continued on next page
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6 | THE VIRGINIA INDEPENDENT NEWS | Q1 2021