05
November
2025

Top 5 Things to Keep You Out of Hot Water in an Audit

Prepare for audits with these essential tips, including maintaining professionalism, using state-specific documents, and addressing complaints seriously. Stay informed to ensure compliance and minimize risks in your
dealership.

Top 5 Things to Keep You Out of Hot Water in an Audit

You see a vehicle pull onto your lot and the very professional looking person who approaches your door is not carrying themselves like your normal customer… your heart skips a beat and you just KNOW… it’s an AUDITOR. YIKES!

Here are the TOP 5 things that ANY auditor from ANY department, regardless of your location, are currently keying in on:

  1. NEVER argue with an auditor from ANY Federal or State agency! Thank them for their time, provide them with the documents they request, be polite. Even if they seem less than friendly, they can only report what they find – if you become agitated or confrontational, they may think you are trying to hide something and dig deeper than usual. No matter the findings, you have the right to arbitration or appeal based on your jurisdiction.
  2. Be sure that you are using documents in your deals that are STATE SPECIFIC to the CORRECT state! Especially in CT, IL, MD, NY & PA, where many former CFPB officials have found new positions with the Attorney General’s offices, auditors are paying close attention to Buyer’s Orders, Contracts and Disclosures. A simple mistake may lead to a parade of other auditors & fines.
  3. EVERY VEHICLE on your sales lot NEEDS to have either an FTC Sticker (“AS IS”/Warranty Label) or a “Not for Sale” sticker! As soon as a vehicle is taken in trade, comes off a transport or arrives on your lot from auction - before it even goes through detail – either throw a “Not for Sale” sticker on it or write “Not for Sale” on the windshield or driver’s window. When detail & prep have been completed, replace with the CORRECT FTC Sticker. Be sure to consult with your service contract/warranty provider on exactly what you are offering and how it should be identified on the label if indicating anything other than “AS IS”. (Service Contracts are NOT Warranties!)
  4. Take EVERY COMPLAINT VERY SERIOUSLY – the Attorneys General DO! Have a WRITTEN plan in place to address different kinds of complaints (advertising, discrimination, mechanical, etc). This policy should also assign a clear individual or position responsible and chain of authority to respond and take action. Attorneys General keep an ongoing record of ALL consumer complaints, even those that are unfounded.
  5. OFAC, RED FLAG RULES & protection of PII are HOT BUTTON items with auditors! When an auditor walks in, they WILL ask you to produce your WRITTEN POLICIES – be prepared to hand them a prepared binder and smile. You’ve got this!

Please be VERY AWARE that regardless of the entity the auditor identifies themselves with, in this climate of “DE-REGULATION”, each one is looking out for infractions and will be notifying the appropriate Federal or State agency to come to YOUR dealership to take a closer look at what they think they found.

Not sure where you measure up with compliance? MidAtlantic IADA offers a “mock” audit review starting at $995 – please contact Kathy at 717-238-9002 to schedule yours today. Steve Levine with our Preferred Vendor, Ignite Consulting Partners, will be happy to review your dealership needs. He is available at (817) 803-3143.

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Categories: Dealer News Stories

Steve Levine

Steve Levine

Steve Levine is an auto finance lawyer with over 30 years of experience protecting car dealers and finance companies. He is an owner and Chief Legal and Compliance Officer of Ignite Consulting Partners, which offers guidance on compliance, operations and best practices. He has also published two books, Winning the Fight: A Guide to Protect Car Dealers and Counterpunch: Compliance Strategies for Car Dealers which are both available on Amazon. Or contact info@IgniteCP.com to learn more. Please follow Steve on X @LawyerLevine for compliance and industry related content.

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