By: Myril Shaw – Shaw Consulting US 



Let’s start here:

“Going forward, the CFPB intends to consider good faith, company size, and all other factors it typically considers as it uses its prosecutorial discretion.”

 -- Consumer Financial Protection Bureau Rescinds Abusiveness Policy Statement to Better Protect Consumers

MAR 11, 2021

The CFPB is the Consumer Finance Protection Bureau. In conjunction with the FTC, they work to ensure that all consumer rights, and protections, are being properly ensured and enforced at all stores. Today, these apply particularly to identity theft and identity fraud, as well as other more significant and complex issues, such as money laundering and doing business with individuals, groups, and organizations prohibited by the US Government.

How does this matter to you?

Are you ensuring that there is no possibility of anyone stealing another customer’s identity at your store (sadly, that also includes by employees)? Are you doing everything to verify the customer’s identity (are you ever in a hurry)?

Are you doing and documenting all your cash transactions? Are you tracking and reporting all cumulative $10,000+ transactions? Are you checking all potentially substantive cash transactions for possible OFAC violations?

Of course, you say. And what happens when “of course” turns into “oh no!”

Suddenly there is an identity theft for one of your customers. You realize, too late, that the customer you sold to was not who they said they were. You sold to a prohibited buyer. You inadvertently cooperated in a money laundering activity.

It sounds impossible. It can happen.

When it does, you want cooperation from and not accusation by the government. That is where “good faith” comes in/

“Good faith” means that you have done everything that can, should and can document in all forms of Compliance.

·       You have the Compliance manuals signed, printed, and displayed

·       You have a designated Compliance Officer

·       You have proof of training of all employees

·       You have a demonstrable training program – including signatures in the Compliance Manuals when training completed

·       You have proof, by signature, of the commitment of Ownership and Senior Management to the Compliance requirements

With all “good faith” in place, there may still be challenges – you will be in the position to fend them off and win.

Demonstrate “good faith” and protect your profit and your store.

Start today!!!

Shaw Consulting US – Helping You Maximize Profit and Minimize Risk Every Day 

Shaw Consulting US, LLC can help you achieve F&I excellence and Compliance safety – or at least a demonstrable “good faith effort” in Compliance - no matter where you are in the development and/or maturity of your store or stores F&I success / Compliance Effectiveness models. The Founders have helped lead dealers and Service Providers to achieve the highest levels of “per unit F&I profit” and have significant experience and success in equipping and training dealers in Compliance best practices. 

We train, consult, provide tools and documents, and can help source the best people. We can also assist in building out the best systems for delivering both F&I profit and Compliance best practice. Whatever you need, Shaw Consulting US is here for you.

Visit our website (and see our Blog posts) at https://shawconsultingus.com, contact us at info@shawconsultingus.com, find out about our special Comprehensive Compliance Program at compliancespecial@shawconsultingus.com, or just give us a call at (678) 641-8419.

Whether it is maximizing F&I Profit or minimizing Compliance risk, or both, or a combination Shaw Consulting US, LLC an help you be your best (https://shawconsultingus.com)

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