By: Denis-Andrei Mesinschi, Esq.
January 17, 2014.
In a fast-moving act by the Federal Trade Commission (FTC) that can justly be called a "crack-down", ten (10) automobile dealers of varying size and sophistication were charged with violations of various consumer protection laws. The charges by the FTC stemmed from differing allegations of deceptive or misrepresentative advertising or conduct related to the Dealerships' sales promotions. On January 9th the the FTC, following what appears to have been a lengthy investigation, publicized the charges. In its recent article on the topic, the Automotive News quoted Jessica Rich, Director of the FTC's Bureau of Consumer Protection, who warned that "many others" will follow.
To Be Expected?
For those in the auto industry, particularly those familiar with Franchise Dealership operations, it may come as no surprise that this happened - it was bound to happen eventually. Between the pressure on Franchise Dealerships to hit monthly sales targets; to the constant "belt-tightening" at Dealerships that often cuts out proper legal oversight and review, to merely the fast-pace of business in the industry itself. All three factors create an environment where bad conduct and mistakes are likely to happen.
The cynical amongst us will also suggest that this is accepted practice in the Automotive Industry -- that the stereotype of the slimy "buy buy buy" car (especially the 'used car') dealer has a well deserved root. Unfortunately that reputation really isn't as well deserved as one might think these days. Most modern, sophisticated, dealerships know their client-base and know that its the long-term benefits of returning customers or (the ideal) the returning customer that recommends you, are attainable only through more upfront and collaborative sales tactics: Less "three card monty" and more "Monty Hall". Sure, there are still the slippery dealers out there with gimmicky ads that yell at you from the TV screen at 2am urging you to "run, don't walk" over to their facility... but they're, thankfully, a dying breed.
To Be Expected?
For those in the auto industry, particularly those familiar with Franchise Dealership operations, it may come as no surprise that this happened - it was bound to happen eventually. Between the pressure on Franchise Dealerships to hit monthly sales targets; to the constant "belt-tightening" at Dealerships that often cuts out proper legal oversight and review, to merely the fast-pace of business in the industry itself. All three factors create an environment where bad conduct and mistakes are likely to happen.
The cynical amongst us will also suggest that this is accepted practice in the Automotive Industry -- that the stereotype of the slimy "buy buy buy" car (especially the 'used car') dealer has a well deserved root. Unfortunately that reputation really isn't as well deserved as one might think these days. Most modern, sophisticated, dealerships know their client-base and know that its the long-term benefits of returning customers or (the ideal) the returning customer that recommends you, are attainable only through more upfront and collaborative sales tactics: Less "three card monty" and more "Monty Hall". Sure, there are still the slippery dealers out there with gimmicky ads that yell at you from the TV screen at 2am urging you to "run, don't walk" over to their facility... but they're, thankfully, a dying breed.
In this case, it was the timing and swiftness of the FTC action, however, that caught many observers off guard and, with the promise of many more to come, its time for Dealers and OEMs alike to take stock of their practices and make sure they're complying with the various consumer protection laws out there.
Who's Fault is It Anyway?
For the lay person its all to easy to shrug this off as a group of uncrubulous crooks and tweed-wearing-used-car-dealers just trying to rip people off. That may well be the case. However, there are a number of actors who could easily have been to blame - at least in part - for these particular ads but, also, for the overall state of the industry's marketing strategies.
For the lay person its all to easy to shrug this off as a group of uncrubulous crooks and tweed-wearing-used-car-dealers just trying to rip people off. That may well be the case. However, there are a number of actors who could easily have been to blame - at least in part - for these particular ads but, also, for the overall state of the industry's marketing strategies.
1. The Dealer Principal and General Managers.
At the end of the day responsibility for what any dealership does lies with the Dealer Principal and the General Sales Manager. The Dealer Principal, the owner of the dealership (and often the group of dealerships) is responsible for hiring their stores' General Managers and setting expectations for how the business should be run and the manner in which customers should be treated -- and by extension how they should be marketed to. The Dealer Principal is also the one that SHOULD be requiring that the dealership's lawyers review important legal items such as advertising mouse-print.
The General Managers are generally the folks who are responsible for running any particular store's operations. Typically the advertising goes through them and the types of ads run is determined by the General Manager. The General Manager should be the one to make sure that all advertising that is run has been verified by the dealership's legal counsel before sending it out publication.
Both these players are ultimately responsible when advertisements are misleading customers and, for the most part, the FTC seems to agree. All of the charges here were leveled directly against the Dealerships themselves -- despite the fact that all, but two, of the dealers involved were Franchise Dealers selling new, rather than used, cars.
The two private dealers, Casino Auto Sales and Rainbow Auto Sales, are the ones that may be easiest to understand. Small used-card dealerships often do not have the budget to afford either a full-time in-house counsel (as many large dealer groups have) or to have an experienced automotive lawyer on retainer. As such most used-car dealers do the best they can with what they know. The advertisements which got Casino Auto Sales and Rainbow Auto Sales could be seen as either (1) unscrupulous sales tactics trying to "pull one over" on the consumer; or (2) simply mistakes caused by simply not knowing any better and not having the wherewithal (financially or experientially) to have their advertising reviewed by lawyers first.
With the bigger franchise dealers, however, there could be fault to lay at the foot of the Manufacturers (OEMs):
2. The Manufacturers (for Franchised Dealerships).
Of the Dealers charged in this round of FTC enforcement actions, eight (10) Dealer groups of the ten (10) were franchised dealers. These were business that have signed very complex legal documents with franchise owners (the manufacturers/OEMs) to sell new vehicles under the brand-name of the OEM. The franchise agreements also set out the advertising standards and protocols to be followed. It would be too easy to brush off these particular incidents as a few rouge dealers going off the proverbial "reservation". However, there may be something more here that suggests a broader problem at some of North America's biggest brands. Typically advertising campaigns and ad-copy are prepared by Head Office staff at the OEM's marketing departments -- they provide template mouse prints and, often, even the adcopy itself. This may well have been where Norm Reeves Honda got the "template" it blamed. Dealers often don't think twice about putting to publication adcopy provided by the OEM which is a mistake.
While some OEMs have very well-organized legal protocols in place with large in-house legal departments staffed with lawyers that not only know the law but -- far more importantly -- know the automotive business and where all ad copy is reviewed. That was the case during my tenure as Legal Counsel for Dealer Development but it was a protocol that myself and the General Counsel had to implement as it didn't exist beforehand. The same holds true for some of the large OEMs now -- some of the biggest players in the industry have small or understaffed in-house legal departments that are often so overworked with Dealer-Relations; Product Liability; Warranty; Trademark; Environmental; Compliance and a myriad of other legal issues that they simply don't get around to reviewing adcopy (which changes several times in a given month). Instead management typically bypasses the legal department altogether and leaves the adcopy and the all important disclosures to the marketing department which, speaking from experience, tends to fall to the lowest person on the totem pole to review. This unfortunately also means that its the least experienced person that's actually looking at what is ultimately very important legal language. It is unfortunately not until a mistake is made that the Legal Department is notified and, at that point, the damage is done and the company is in a defensive posture.
The brands caught up in this round of FTC enforcement were very well known, and otherwise, sophisticated brands with big marketing machines behind them:
While some OEMs have very well-organized legal protocols in place with large in-house legal departments staffed with lawyers that not only know the law but -- far more importantly -- know the automotive business and where all ad copy is reviewed. That was the case during my tenure as Legal Counsel for Dealer Development but it was a protocol that myself and the General Counsel had to implement as it didn't exist beforehand. The same holds true for some of the large OEMs now -- some of the biggest players in the industry have small or understaffed in-house legal departments that are often so overworked with Dealer-Relations; Product Liability; Warranty; Trademark; Environmental; Compliance and a myriad of other legal issues that they simply don't get around to reviewing adcopy (which changes several times in a given month). Instead management typically bypasses the legal department altogether and leaves the adcopy and the all important disclosures to the marketing department which, speaking from experience, tends to fall to the lowest person on the totem pole to review. This unfortunately also means that its the least experienced person that's actually looking at what is ultimately very important legal language. It is unfortunately not until a mistake is made that the Legal Department is notified and, at that point, the damage is done and the company is in a defensive posture.
The brands caught up in this round of FTC enforcement were very well known, and otherwise, sophisticated brands with big marketing machines behind them:
- Hyundai/Kia Motors America - (4)
- Honda - (2)
- Ford - (2)
- Nissan/Infiniti - (2)
- Mitsubishi - (1)
What will be interesting is to see who the next round of dealers (and OEMs they represent) will be caught up in the FTCs enforcement actions. If the same brands continue to come up, then the likelihood is that fault, at least some of it, rests with the OEMs and some uncomfortable discussions may have to start to be had in OEM boardrooms across the country.
4. The Marketing Agencies.
On occasion a dealership will farm out all of its marketing to specialist marketing companies. In fact, even OEMs to this all the time. Its these marketing agencies that come up with clever and kitschy advertisements for TV with everything from hamsters driving cars to sleek coupes driven by improbably handsome people zipping through an equally improbably empty New York City. However these companies also often design and write the disclosure statements.
Larger, sophisticated (and expensive) advertising agencies have in-house counsel that reviews (or should review) the mouse print and typically they do a fair enough job of it. The smaller, local, companies, however rarely have any sort of in-house legal support and its unlikely they're willing to pay any part of their, often small, production budget to have a lawyer review the mouse print. So, most often, when advertising agencies do provide the disclosures they use a template that someone, at some point, wrote for them and that they try to tweak to be reflective of whatever the promotion of the day is. This can mean that the language doesn't adequately describe the terms of the promotions and, consequently, is deceptive when viewed by the public.
Thought ultimately the Dealership (or the OEM if the advertising is prepared for OEM use) is still responsible but the advertising agencies have a hand in what gets out to the public as well.
5. The Lawyers.
Finally, the Lawyers have a hand in this also. All across the country there are local lawyers and big firms alike that represent Dealer Groups. Most do a fair enough job of it and some shouldn't be in the business at all. But that's like anything else.
The challenge is that there are only a very few lawyers out there that actually have an understanding of the Automobile Industry and what the day-to-day business of either an OEM or a Dealership is like so they're often ill-equipped to provide preventative counsel. Most "outside" counsel to the automotive industry in North America are not from the Automotive industry but are law-firm bred lawyers whose focus is litigation and billable hours. With this focus they rarely give a thought to the pragmatics of the business situation -- in fact they couldn't since, all too often, they simply don't understand the business realities on the ground.
I witnessed this first hand while working as Legal Counsel for one of the larger OEMs. When, following the original protocols then in place, we sent a moderately complex matter with a claim of something around $50,000.00 to one of Toronto's biggest law firms (from whom the General Counsel had come, and which we routinely used for such matters) for a "quick" evaluation of the law surrounding the issue. When the bill came through, at the eye-watering amount of $25,000.00, and after management OEM had several heated exchanges -- and a handful of the more colorful lawyer slurs I've heard -- the matter was brought back to the firm which is when we all realized the problem: the firm in question -- while fantastic for litigation -- knew about as much about the business considerations of the auto-industry as the typical JiffyLube employee knows about complex brain surgery.
As we subsequently did, OEMs are relying more and more on their in-house legal departments, realizing significant savings along the way in both financial terms and operational ones. In-house lawyers for the Auto Industry, when properly empowered, become a vital contributor to the day-to-day operations of the business -- they're able to spot issues BEFORE they become a problem -- something outside counsel can simply never do: they don't know the business well enough and they're just don't there every day.
Dealerships have a harder time replicating this for two reasons: first, there are few Automotive Lawyers in private practice (most who've gotten into the business and survived never leave); and, second, they often cannot afford to keep an in-house lawyer (with average salaries for Automotive Lawyers in the $250K+ range). The solution then, is to have the outside lawyers that represent automotive businesses spend the time to learn the business of their clients. Work out some sort of financial arrangement where the lawyer can audit the operations to learn not only the business itself but the way in which their client carries on business. We do this as a matter of course for each new Automotive Client and the audits usually bring up a handful of practices that can be easily improved or modified to avoid some of the very same issues that seem to have placed these ten dealers in the FTC's sites.
On occasion a dealership will farm out all of its marketing to specialist marketing companies. In fact, even OEMs to this all the time. Its these marketing agencies that come up with clever and kitschy advertisements for TV with everything from hamsters driving cars to sleek coupes driven by improbably handsome people zipping through an equally improbably empty New York City. However these companies also often design and write the disclosure statements.
Larger, sophisticated (and expensive) advertising agencies have in-house counsel that reviews (or should review) the mouse print and typically they do a fair enough job of it. The smaller, local, companies, however rarely have any sort of in-house legal support and its unlikely they're willing to pay any part of their, often small, production budget to have a lawyer review the mouse print. So, most often, when advertising agencies do provide the disclosures they use a template that someone, at some point, wrote for them and that they try to tweak to be reflective of whatever the promotion of the day is. This can mean that the language doesn't adequately describe the terms of the promotions and, consequently, is deceptive when viewed by the public.
Thought ultimately the Dealership (or the OEM if the advertising is prepared for OEM use) is still responsible but the advertising agencies have a hand in what gets out to the public as well.
5. The Lawyers.
Finally, the Lawyers have a hand in this also. All across the country there are local lawyers and big firms alike that represent Dealer Groups. Most do a fair enough job of it and some shouldn't be in the business at all. But that's like anything else.
The challenge is that there are only a very few lawyers out there that actually have an understanding of the Automobile Industry and what the day-to-day business of either an OEM or a Dealership is like so they're often ill-equipped to provide preventative counsel. Most "outside" counsel to the automotive industry in North America are not from the Automotive industry but are law-firm bred lawyers whose focus is litigation and billable hours. With this focus they rarely give a thought to the pragmatics of the business situation -- in fact they couldn't since, all too often, they simply don't understand the business realities on the ground.
I witnessed this first hand while working as Legal Counsel for one of the larger OEMs. When, following the original protocols then in place, we sent a moderately complex matter with a claim of something around $50,000.00 to one of Toronto's biggest law firms (from whom the General Counsel had come, and which we routinely used for such matters) for a "quick" evaluation of the law surrounding the issue. When the bill came through, at the eye-watering amount of $25,000.00, and after management OEM had several heated exchanges -- and a handful of the more colorful lawyer slurs I've heard -- the matter was brought back to the firm which is when we all realized the problem: the firm in question -- while fantastic for litigation -- knew about as much about the business considerations of the auto-industry as the typical JiffyLube employee knows about complex brain surgery.
As we subsequently did, OEMs are relying more and more on their in-house legal departments, realizing significant savings along the way in both financial terms and operational ones. In-house lawyers for the Auto Industry, when properly empowered, become a vital contributor to the day-to-day operations of the business -- they're able to spot issues BEFORE they become a problem -- something outside counsel can simply never do: they don't know the business well enough and they're just don't there every day.
Dealerships have a harder time replicating this for two reasons: first, there are few Automotive Lawyers in private practice (most who've gotten into the business and survived never leave); and, second, they often cannot afford to keep an in-house lawyer (with average salaries for Automotive Lawyers in the $250K+ range). The solution then, is to have the outside lawyers that represent automotive businesses spend the time to learn the business of their clients. Work out some sort of financial arrangement where the lawyer can audit the operations to learn not only the business itself but the way in which their client carries on business. We do this as a matter of course for each new Automotive Client and the audits usually bring up a handful of practices that can be easily improved or modified to avoid some of the very same issues that seem to have placed these ten dealers in the FTC's sites.
The Dealers, the Charges, and the Settlements:
According to the Automotive News, the dealerships which eventually settled with the FTC were as follows:
Norm Reeves Honda Superstore
Cerritos, California
Norm Reeves Honda Superstore
Cerritos, California
- The ads run by Norm Reeves Honda Superstore (NRHS) allegedly violated the FTC Act, according to the FTC, by "deceptively advertising that consumers could pay $0 up-front to lease a vehicle when, in fact, the advertised amounts excluded substantial fees and other amounts".
- NRHS also allegedly violated the Consumer Leasing Act and Regulation "M" by failing to disclose certain lease related terms.
- Finally, NRHS was alleged to have violated the Truth in Lending Act and Regulation "Z" by not disclosing certain credit related terms.
- NRHS, which, according to the Automotive News, was Honda's top selling franchise in the United States, claimed the error occurred when the dealership relied on "a standard disclosure template" it had obtained from unidentified sources that were used in an advertisement that was run in March, 2013.
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
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| - Norm Reeves Honda Superstore Advertisement cited by FTC - |
Los Angeles, California
- According to the FTC, Honda of Hollywood (HoH) allegedly violated the FTC Act, by "deceptively advertising that consumers could pay $0 up-front to lease a vehicle when, in fact, the advertised amounts excluded substantial fees and other amounts", and the Consumer Leasing Act and Regulation "M"
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Hollywood Honda Advertisements cited by FTC - |
Morrow, Georgia
- According to the FTC, Nissan of South Atlanta (NoSA) violated the FTC Act, by "advertising that consumers could finance a vehicle...with low monthly payments when, in fact, the payments were temporary 'teasers' after which consumers would owe a different amount".
- The advertisements run by NoSA also allegedly violated the Truth in Lending Act and Regulation "Z" by not disclosing certain credit related terms.
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Nissan of South Atlanta Advertisement cited by FTC - |
Claredon Hills, Illinois
- The FTC alleged that Infiniti of Claredon Hills (ICH) allegedly violated the FTC Act by "advertising that consumers could pay $0 up-front to lease a vehicle when, in fact, the advertised amounts excluded substantial fees and other amounts.
- The advertisements run by ICH also allegedly violated the Consumer Leasing Act and Regulation "M" by failing to disclose certain lease related terms.
- The Automotive News reported ICH's Executive Manager Peter Korallus as explaining that ICH "committed an oversight when we used the term 'no money down' in our ads, when the FTC does not consider collecting licensing, taxes and other fees to be no money down". ICH reportedly has changed their ad and promised to "be more diligent in the future".
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Infiniti of Claredon Hills Advertisements Cited by FTC - |
Hickory North Carolina
- According to the FTC, Paramount Kia (PK) violated the FTC Act, by "advertising that consumers could finance a purchase with low monthly payments when, in fact, the payments were temporary 'teasers' after which the consumer would owe a much higher amount, by several hundred dollars."
- The advertisements also allegedly violated the Truth in Lending Act and Regulation "Z" by not disclosing certain credit related terms.
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Paramount Kia Advertisement cited by FTC- |
Fowlerville, Michigan
- The FTC, alleged that Fowlerville Ford (FF) violated the FTC Act by "sending mailers that deceptively claimed consumers had won a sweepstakes price, when, in fact, they had not."
- The advertisements also allegedly violated the Truth in Lending Act and Regulation "Z" by not disclosing certain credit related terms.
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Fowlerville Ford Advertisement cited by FTC - |
Group of companies, including:
- New World Auto Imports - Dallas, Texas
- New World Auto Imports - Rockwell, Texas
- Hampton Two Auto Corp. - Mesquite Texas
- The Southwest Kia Group (SKG) allegedly violated the FTC Act by:
- "deceptively advertising that consumers could purchase a vehicle for specific low monthly payments when, in fact, consumers would owe a final ballon payment of over $10,000."
- "deceptively advertis[ing] that consumers could drive home a vehicle for specific low up-front amounts and low monthly payments when, in fact, the deal was a lease and they would owe substantially more up-front"
- The advertisements also allegedly violated the Consumer Leasing Act and Regulation "M" by failing to disclose certain lease related terms.
- Furthermore, the advertisements allegedly violated the Truth in Lending Act and Regulation "Z" by not disclosing certain credit related terms.
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Southwest Kia Advertisements cited by FTC - |
La Puente, California
Rainbow Auto Sales
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Casino Auto Sales Advertisement cited by FTC - |
South Gate, California
[See the Charges] [See Proposed Settlement] [Comment on Settlement] [Follow the Case]
 |
| - Rainbow Auto Sales Advertisement cited by FTC - |
Settlement:
The nine (9) dealers discussed above were all able to come to provisionary settlement agreements with the FTC, known technically as "consent orders", the proposed settlements generally prohibit violations of the FTC Act by barring dealerships:
"from misrepresenting any advertisement for the purchase, financing, or leasing of motor vehicles, the cost of leasing a vehicle the cost of purchasing a vehicle with financing, or any other material fact about the price, sale, financing, or leasing of a vehicle"
Provisions would also address and Truth in Lending Act or Consumer Leasing Act violations.
The prohibitions would be in effect for twenty (20) years and their violation could result in serious financial repercussions against the dealers.
The FTC is keeping an open comment period for each individual settlement where consumers affected by the specific violations may voice their concerns. (See the corresponding links above for more information.)
The prohibitions would be in effect for twenty (20) years and their violation could result in serious financial repercussions against the dealers.
The FTC is keeping an open comment period for each individual settlement where consumers affected by the specific violations may voice their concerns. (See the corresponding links above for more information.)
Continuing to Trial:
Whereas the other nine (9) dealerships were able to settle with the FTC, it appears that Courtesy Auto Group of Attleboro Massachusetts (CAG)was either unable or unwilling to do so. As a result, the FTC, in a 4-0 vote in favor, issued an "Administrative Complaint" against CAG alleging that the it:
- "violated the FTC Act by deceptively advertising that consumers can lease a vehicle for $0 down and specific monthly payments when, in fact, the advertised amounts exclude substantial fees."
- furthermore, the FTC com plait alleges that the advertisements "allegedly violate the Consumer Leasing Act and Regulation "M", by failing to disclose or clearly and conspicuously disclose certain lease related terms."
The issuance of the "Administrative Complaint" marks the first step in proceedings against Courtesy Auto Group which will lead to a formal trial and hearing before an Administrative Law Judge (ALJ).
The complaint itself sets out a list of Orders (which the FTC is requesting the ALJ issue and which Courtesy Auto Group will doubtlessly challenge at the upcoming hearing) that Courtesy Auto Group must comply. As written the orders would be in effect for twenty (20) years and, in general terms, require Courtesy Auto Group to:
- not misrepresent costs related to vehicle purchasing
- not misrepresent costs related to vehicle leasing
- not misrepresent any material fact about the price, sale, financing, or leasing of any vehicle.
Once approved by the ALJ, should Courtesy Auto Group fail to adhere to the Orders of the FTC, the FTC will have the right to seek damages in accordance with Section 19(b) of the FTC Act that permit the Courts to "grant such relief as the court finds necessary" and includes and, or all, of the following:
- recession of contracts
- reformation (amendment) of contracts
- refund of money
- return of property
- payment of damages
- public notification respecting the rule violation or deceptive act
[See the Administrative Complaint] [Follow the Case]
Final Thoughts.
While we wait to see what other Dealerships the FTC will target, Franchise and Independent dealers as well as OEMs across the country should be looking to their marketing practices and having their legal representatives evaluate them to ensure compliance with consumer protection laws. The FTC has indicated that this is just the beginning of an action that may well affect a great many dealers throughout the country.
If you're an Automotive Dealer that would like assistance reviewing your marketing materials for FTC compliance, or for general assistance with your dealership's operations, contact Attorney Denis-Andrei Mesinschi for a business evaluation and let us show you how we can help your business thrive in today's increasingly competitive, and regulated, marketplace.
Mesinschi Law Offices
1-888-516-4298
www.canamlegal.com
ABOUT ATTORNEY DENIS-ANDREI MESINSCHI.
Attorney Mesinschi is an attorney licensed to practice law in several states within the United States and Canada and founder of the Mesinschi Law Offices, a boutique cross-border law firm that caters to the business community and maintains one of the few active automotive-specific practices in North-America. As a life-long, dyed-in-the-wool, car fanatic, Attorney Mesinschi's started in the automotive industry at the age of sixteen at an automotive parts desk, worked on an automotive assembly line through undergrad and, at the age of 24, became one of the youngest corporate counsel in the Canadian automobile industry's history. Attorney Mesinschi works with Dealerships, OEMs, suppliers, and other actors in the automotive industry providing experienced legal counsel, business and operational consulting services.
ABOUT THIS BLOG.
The Automotive Blog @ Mesinschi Law Offices is a blog dedicated to all things automotive. We will feature legal articles and analysis relating to the automotive industry and consumers but will also feature opinion articles on vehicles, business matters and any manner of topic that might be of interest to car lovers. From time-to-time we will invite guest contributors and remind our readers that the opinions and views expressed by the authors do not necessary reflect the views of the Mesinschi Law Offices, its staff, or associates. -- Enjoy.
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| - Courtesy Kia Advertisements cited by FTC - |
Final Thoughts.
While we wait to see what other Dealerships the FTC will target, Franchise and Independent dealers as well as OEMs across the country should be looking to their marketing practices and having their legal representatives evaluate them to ensure compliance with consumer protection laws. The FTC has indicated that this is just the beginning of an action that may well affect a great many dealers throughout the country.
If you're an Automotive Dealer that would like assistance reviewing your marketing materials for FTC compliance, or for general assistance with your dealership's operations, contact Attorney Denis-Andrei Mesinschi for a business evaluation and let us show you how we can help your business thrive in today's increasingly competitive, and regulated, marketplace.
Mesinschi Law Offices
1-888-516-4298
www.canamlegal.com
ABOUT ATTORNEY DENIS-ANDREI MESINSCHI.
Attorney Mesinschi is an attorney licensed to practice law in several states within the United States and Canada and founder of the Mesinschi Law Offices, a boutique cross-border law firm that caters to the business community and maintains one of the few active automotive-specific practices in North-America. As a life-long, dyed-in-the-wool, car fanatic, Attorney Mesinschi's started in the automotive industry at the age of sixteen at an automotive parts desk, worked on an automotive assembly line through undergrad and, at the age of 24, became one of the youngest corporate counsel in the Canadian automobile industry's history. Attorney Mesinschi works with Dealerships, OEMs, suppliers, and other actors in the automotive industry providing experienced legal counsel, business and operational consulting services.
ABOUT THIS BLOG.
The Automotive Blog @ Mesinschi Law Offices is a blog dedicated to all things automotive. We will feature legal articles and analysis relating to the automotive industry and consumers but will also feature opinion articles on vehicles, business matters and any manner of topic that might be of interest to car lovers. From time-to-time we will invite guest contributors and remind our readers that the opinions and views expressed by the authors do not necessary reflect the views of the Mesinschi Law Offices, its staff, or associates. -- Enjoy.
