Compliance is all we do.
CONTENT
ABOUT AAS
3. AAS Mission
3. Our Background
4. Team Overview
OUR SERVICES
6. Service Drive Audits
7. Sale and Finance
8. California Hotline
9. Advertising Review
10. Litigation Support and In-house Seminars and Training
PRICING
11. Hotline Service
11. Advertising Review
11. Sales and Finance Audits
11. Service Drive Audits
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AAS MISSION
To provide retail automotive dealerships with accurate, comprehensive, and
highly specialized sales, finance, service drive, and advertising compliance
services and products delivered and developed by extensively trained and
experienced personnel of the utmost moral character.
Auto Advisory Services (AAS) has been providing assistance to
California automobile dealers since 1975. We are dedicated to
providing the most comprehensive compliance services and
products available. Our business has grown and expanded
largely by referral of one dealer to another. Our client base
consists of over 500 California dealerships, including dealers
from the largest dealer groups in the country and a growing
number of dealerships outside California.
AAS was established by Bill Lowrey. As a former special
investigator for the DMV, Bill discovered many dealers were
simply unaware of the legal complexities involved with doing
business in California. He then partnered with attorney, Mike
Michaelis, and together they set out to build a company with
one purpose: to help dealerships prevent small compliance
problems from becoming large litigation or administrative
headaches.
Today AAS is the leader in dealership compliance issues. Our
auditors typically perform over 70 audits per month. Our
Hotline receives, on average, over 500 calls per month.
Our team is comprised of:
– Compliance Attorneys
– Former DMV investigators and area commanders
– Former DMV occupational licensing inspectors
– A former DMV Deputy Chief of Investigations
– Former BAR program representatives
– Vehicle registration technicians
Each of our consultants is armed with many years of industry
experience and all consultants are extensively trained and
tested. The end result: solid advice you can trust to reduce
your exposure to enforcement activity and litigation.
Unlike many companies, AAS does not oer any F&I products.
We are decisively independent and will provide you with
an uncompromised and critical look into your finance
department.
We oer many services and products, all geared towards
helping dealers comply with the maze of regulations and laws
aecting dealership operations today.
Our services and products include:
– Compliance Hotline
– On-site Sales, F&I, and Service Drive Compliance Audits
– Advertising Review
– Periodic Compliance Newsletter
– Safeguards Rule Implementation
– On-site Vehicle Registration Service
– Educational Seminars and Compliance Training
– Customized In-House Workshops
– Automotive Dealership Privacy, Information Safeguards
& Red Flags Manual
– Litigation Support ( Auditing and Consulting)
No other compliance company maintains a higher level of
technical compliance expertise. Ask around, our reputation is
our greatest asset.
OUR BACKGROUND
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Lisa Singer has worked with AAS in various capacities for more than
fifteen years. Prior to joining AAS, Lisa served as general counsel for a
large automotive group in San Diego, California. Lisa currently oversees
all consulting operations, including our sales and service drive audits,
compliance Hotline, and publications. In addition, Lisa provides on-site
seminars and legal workshops for dealership employees. She received
her B.A. from the University of California, Berkeley and her J.D. from the
University of California, Los Angeles.
From 2011 through 2017, Lisa also worked as a consulting attorney in the
Automotive Practice Group at Arent Fox, LLP (a national law firm). While
there, Lisa drafted commission pay plans, employee handbooks, job
descriptions, warranty documents, and custom forms for both fixed and
variable operations. She reviewed dealership advertising, web applications,
and vendor/lender agreements. Lisa’s background also includes handling
dealership licensing applications, assessing litigation exposure, and
conducting wage/hour and deal jacket audits.
Rob Cohen started with Auto Advisory Services (AAS) in 1994, was
president from 2006 to 2014, and currently serves as chairman. In 2006, Rob
co-founded Motor Vehicle Software Corporation (MVSC), the company that
created DMVdesk. Rob sold his interest in MVSC to Accel-KKR in 2015. In 2011,
Rob joined Arent Fox’s Automotive Industry Practice as Senior Automotive
Counsel. Rob worked as a car salesman and did F&I during law school. He
received his B.A. and M.B.A. from the University of California, Irvine and then
went on to earn his J.D. from Whittier College, School of Law.
Rob is a founding director and past-president of the National Association of
Dealer Counsel (NADC), former editor of The Defender (the NADC newsletter),
and has been published in Ward’s Dealer Business, Orange County Business
Journal and F&I Management and Technology. He is a frequent speaker and
trainer on a wide range of subjects pertaining to dealership sales and finance
compliance. Rob co-authored and published the top-selling Automotive
Dealership Information Safeguards Manual, the Automotive Dealership
Identity Theft Guide, the Automotive Dealership Red Flags Rule Guidebook,
and Auto Dealer Law, First Ed.
Executive Vice President
Chairman, Auto Advisory Services, Inc.
Senior Automotive Counsel, Arent Fox, LLP
Rob Cohen, Esq.
Lisa Singer, Esq.
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MEET
OUR EXPERTS
Jerome Froehlich Hao Nguyen, Esq.
SENIOR COMPLIANCE CONSULTANT
Bill has been an integral part of AAS since joining the team
in 2002. He brings over 30 years of experience working
primarily in consulting, finance, and sales management
positions. Most recently, he has been providing compliance
consulting services to auto dealers in California, Arizona,
and Nevada. Bill received his B.S. from United States
International University in San Diego, and earned his
M.B.A. from the University of Southern California.
Bill Ferguson
Roddy Rodriguez
SENIOR COMPLIANCE CONSULTANT
Roddy started with Auto Advisory Services as a Compliance
Consultant in 2005. Previously, he spent 30 years with the
California Department of Motor Vehicles where his duties included
conducting and directing complex investigations into automotive
industry practices. As a career Investigator with the DMV, Roddy
rose to the rank of Deputy Chief of the Bureau. He is a graduate of
the FBI National Academy and has a B.S. degree in Criminology
from the University of California at Berkeley.
SENIOR REPAIR COMPLIANCE CONSULTANT
Jerry joined Auto Advisory Services in 2015 with
more than 27 years of experience at the California
Bureau of Automotive Repair and was instrumental
in the development of the Bureau’s auto body and air
conditioning regulations. He helped develop the Service
Drive Compliance Program and constantly refines the
service as it expands into auto body and other areas.
Jerry currently provides training seminars throughout
the state and serves on the board of directors of the
California Automotive Business Coalition.
COMPLIANCE ATTORNEY
Hao was one of the main architects behind the company’s new
Service Drive Compliance audit program, which focuses on legal
compliance in the automotive repair industry. Having successfully
launched the program in 2016, he has since focused his attention
on the wider automotive landscape as a regular contributor to
the Auto Advisory Services newsletter, compliance hotline, and
advertising review service. Hao received his B.A. in Economics from
the University of California at Davis and his J.D. and M.B.A. from
Santa Clara University. Prior to joining Auto Advisory Services, Hao
was Sta Counsel at the California New Car Dealers Association in
Sacramento and most recently worked with them to publish the
first edition of the Service Drive Compliance Manual and Reference
Guide, which is the first of its kind in the state.
DIRECTOR OF OPERATIONS
Michelle has been an essential member of Auto Advisory
Services since 2007. Through her leadership and
commitment to Auto Advisory Services, she climbed
the ranks to her current role of Director of Operations.
Michelle oversees accounting, human resources, sales
and marketing and client relations. She earned an A.A.
degree from Golden West College.
Michelle Terry
The Compliance Audit
The Bureau of Automotive Repair (BAR) is an entity
within the Department of Consumer Aairs that
oversees repair facility licensing and both statutory
and regulatory enforcement. In our compliance audit,
a former BAR enforcement oicial will review your
operations, focusing on elements with the highest levels
of exposure. At the conclusion of the comprehensive
review, any issues regarding current noncompliance and
possible preventative measures will be communicated to
management. Our auditors will perform a thorough audit
in a non-intrusive manner—allowing your sta to function
without disrupting your daily operations. The compliance
audit involves the following key areas:
1. Enhanced Simulated BAR Facility Inspection: We
will inspect for service department licenses, signs, and
notices required by BAR and other government agencies,
and identify evidence of non-compliant practices.
2. Review of Repair Documentation: We will scrutinize
your repair files against dozens of technical requirements
involved with building initial and revised estimates,
documenting customer authorization, generating
invoices, and creating required supplemental
documentation. The review also examines dealership
repair forms and their “backers,” while looking for
evidence of overly-aggressive sales of services—a
constant target of law enforcement.
3. Exit Interview: Our auditor will sit down with senior
service department management to review findings
and ask questions related to existing compliance
policies. Management will then have the opportunity
to ask questions about the facility inspection and
documentation review.
The Confidential Audit Report
Aer the audit, a detailed audit report is prepared,
identifying compliance issues by service writer and repair
file. This allows management to pinpoint problems for
resolution and identify needed training. Issues with the
highest compliance exposure are separately flagged and
highlighted in an executive summary contained within the
report.
SERVICE DRIVE AUDIT
The service drive audit program
was developed by experienced
automotive repair attorneys and
former BAR oicials, technicians,
and automotive repair compliance
experts.
Let our 200+ years of collective
industry, legal, and law enforcement
experience work for you.
Raising the BAR on Service Department Compliance
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The only way to know whether your dealership is truly compliant
with state and federal law is to look at the documentation that
would be uncovered during a DMV investigation or civil lawsuit.
Our team of attorneys and former DMV Investigators perform
2-day audits of your facilities, inventory, and sign postings
under simulated DMV investigative standards. They will then
review documentation for completeness and compliance,
and interview senior sta about the existence and content of
mandatory and recommended dealership compliance policies.
This service assists dealers in complying with the bevy of laws
and regulations pertaining to sales, finance, and DMV work.
Although audits yield significant information about dealership
compliance they are designed to be low impact: requiring only
minimal interaction with dealership personnel.
Simulated Government Agency Inspection
This element of our audit is an enhanced version of the inspection
protocols used by the DMV in examining the public areas of the
dealership, license and sign posting, and vehicle displays and
labeling. We know what DMV investigators and inspectors are
looking for, and our audit seeks to find problems before they do.
Transaction Documentation (“Deal Jackets”) Review
Our audits examine hundreds of documentation requirements,
with areas of high exposure being clearly dierentiated from
less-severe concerns. We will review a sampling of jackets
from dierent F&I Managers. Each review involves a survey of
a significant number of actual sales over a specified period of
time. Our highly trained auditors look for potential problems
in areas that include, but are not limited to, advertising, vehicle
registration, required disclosures, contract completion, vehicle
representations, unwinds, odometer disclosures and vehicle
transfers.
Policy Review
The existence of and adherence to certain polices cannot always
be determined by reviewing documentation or examining
the public areas of the dealership. As such, we address both
mandatory and recommended policies. At the completion of
the audit, a general meeting is held with personnel designated
by the dealer principal. Ultimately, the dealer is provided with
a comprehensive written report of the findings, with high-
exposure issues highlighted for immediate action.
SALES & FINANCE AUDITS
Inspect What You Expect
We take great care to
ensure our audits do not
interrupt the workflow in
your business oice.
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Our most popular service is our compliance hotline. This service gives dealers the ability to get quick and accurate compliance
information with just a phone call.
The AAS hotline is designed to assist dealers with administrative, regulatory, and compliance issues which commonly arise
during day-to-day operations. The focus of the Hotline is DMV, sales, and F&I regulatory compliance.
Our hotline is currently used by hundreds of new car franchises and has been an invaluable service for over three decades.
The compliance hotline service includes the Auto Advisory Services compliance newsletter. The newsletter provides valuable
information on popular compliance issues aecting the state, suggested best practices to implement at your dealership,
and enforcement activities aecting the broader automotive industry. Combining this service with our compliance audit
program can provide significant overall savings. See Page 11 for pricing details.
Our hotline is staed with compliance experts and experienced attorneys. If legal advice is needed, the services of a
competent professional should be sought. Auto Advisory Services is not a law firm.
The hotline is used by dealership personnel for assistance with such matters as:
– Sales and finance disclosure requirements
– Privacy, Safeguards, and Red Flags issues
– Vehicle registration and transfer questions
– Repossession and unwind issues
– Problem deals
– DMV form utilization
– Industry news and developments
– Allowable contract and DMV charges
– Advertising regulations
– Adverse Action Issues
– Requests for copies of specific laws and/or
regulations
– OFAC questions
– General compliance questions
– Service drive compliance issues
– Requests for AAS publications
CALIFORNIA HOTLINE
Quick and Accurate Compliance Information
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As a subscriber to the Advertising Review Service, you are entitled to submit proofs/scripts of four ads per week for a full
review for compliance with state and federal laws and regulations that govern motor vehicle advertising.
THINGS WE CHECK FOR AND ADDRESS INCLUDE:
– Disclosure terms for financed purchases and leases under Regulations Z & M
– Vehicle description, identification, equipment, and history
– Quantity limitation terms
– Discounts, savings, rebates, and incentives
– Credit qualifying statements
– Warranty advertising
– Mandatory price disclaimers
– Fuel economy claims
– Truthful, accurate, and verifiable claims
ADVERTISING REVIEW
Don’t Advertise Non-Compliance
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For over 40 years, dealers have been using Auto Advisory Services to help reduce exposure to lawsuits and government
enforcement activity. Now, using the Litigation Support service, attorneys who represent dealers can tap the expansive
knowledge base accumulated through our exhaustive research and operational expertise.
The Auto Advisory Services Litigation Support Team oers the following services:
• Litigation Consulting
• Auditing / Document Review
Exposure Assessment
LITIGATION SUPPORT
As part of Auto Advisory Services’ ongoing commitment to provide excellent service to our dealer clients, we oer superbly
informative seminars on a variety of subjects. Topics include our hugely popular “Back to the Basics,” an in-depth look at
the LAW® 553 Retail Installment Sale Contract and other critical documents, Customized Compliance Program, Raising the
BAR – Service Drive Compliance, Privacy, Safeguards and Red Flags, and Advertising Compliance, to name a few. We also
conduct custom in-house seminars tailored to your dealership’s specific needs. Pricing for seminars varies depending on
topic, group size, and location.
IN-HOUSE SEMINARS
AND TRAINING
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HOTLINE SERVICE
Our most popular service is our compliance hotline. This
service gives dealers the ability to get quick and accurate
compliance information with just a phone call. The monthly
fee is $265 per “rooop.
ADVERTISING REVIEW
Provides for a review of up to 4 ads per week (excluding
direct mail pieces) for regulatory compliance.
Ad Review is $135 per month (per “rooop”) in addition
to the compliance hotline, but is not oered as a
standalone service.
PRICE SCHEDULE
SALES & FINANCE AUDITS
Our sales and finance audits include a simulated government
agency inspection, a deal jacket and policy review, an exit
interview, and a written report. A two-day audit is $2,350.
SERVICE DRIVE AUDITS
Our service drive audit includes an enhanced simulated
BAR facility inspection, a review of repair documentation,
an exit interview, and a written report. A two-day audit is
$2,350.
2 - Two-Day Sales/Finance Audits + Compliance Hotline
= $615 per month (Most popular)
2 - Two-Day Sales/Finance Audits + 2 - Two-Day Service
Drive Audits + Compliance Hotline = $965 per month
2 - Two-Day Sales/Finance Audits + Compliance Hotline +
Ad Review = $750 per month
2 - Two-Day Sales/Finance Audits + 2 - Two-Day Service
Drive Audits + Compliance Hotline + Ad Review = $1,100
per month (Recommended)
1 - Two-Day Sales/Finance Audit + Compliance Hotline
= $440 per month
1 - Two-Day Sales/Finance Audit + 1 - Two-Day Service
Drive Audit + Compliance Hotline = $615 per month
1 - Two-Day Sales/Finance Audit + Compliance Hotline +
Ad Review = $575 per month
1 - Two-Day Sales/Finance Audit + Compliance Hotline
+ 1 - Two-Day Service Drive Audit + Ad Review = $750
per month
DISCOUNTED PACKAGE RATES
All of our programs include a subscription to Transmission (the AAS newsletter), the AAS Email Alert Service, and the AAS
Year-End Legislative Summary. A one-year service commitment is required with all subscriptions.
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19100 Von Karman, Suite # 250
Irvine, California 92612
(800) 785-2880
questions@autoadvisory.com
www.autoadvisory.com
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