There are a number of good reasons for operating an ethical and legally compliant dealership, not the least of which is staying out of a courtroom.  Perhaps the most important - and most often overlooked - reason is increased customer satisfaction.  There are times when an employee may feel that he or she came out the winner by bending the rules a little, but what about the dealership’s reputation?  What about the customers who were mislead?  It seems like there might be some losers in the game.

Customers often make decisions during a vehicle sale transaction that they come to regret after the “ether has worn off”.  Perhaps they read the contract more carefully after they got home or showed it to a relative, friend, neighbor, etc.  The customer may notice some imperfections on the vehicle in the light of day and have it inspected by a mechanic or body shop or run a vehicle history report.  If there is a concern, some customers will let the dealer know while others will just chalk it up to (bad) experience.

Now, if the dealer is lucky enough to get a chance to rectify the customer’s concern, how will the complaint be handled?  Will it be “Sorry, all sales are final” or “You signed the contract”?

What about the customer that doesn’t bother to report the concern?  You can be sure they’re telling somebody about the transaction.  Or perhaps they’re telling thousands of people via social media?

Here are some examples of after-sale situations that can cause potential customer satisfaction nightmares:

• The customer sees your advertisement for a price lower than was charged for the vehicle.
• The customer discovers additional charges on the contract for items that he or she thought were included in the price of the vehicle.
• The customer discovers that F&I products were sold at much-higher-than-market prices.
• The customer discovers additional charges on the contract for items that he or she never agreed to purchase.
• The customer gets a call from the lender who asks for verification that the vehicle has a sunroof – and it doesn’t.
• The customer discovers that the price of the vehicle was raised to cover negative equity on the trade-in when after being told that the dealer agreed to purchase the trade-in for the full loan balance.
• The customer gets a call from the lender asking for verification of an income amount which is much higher than what was written on the credit application.
• The customer discovers that the vehicle purchased had undisclosed prior damage.
• The customer runs a vehicle history report and discovers that the vehicle purchased was an undisclosed previous rental, a prior demo, flood damaged, etc.
• The customer brings the vehicle in for repairs and discovers that the warranty or service contract coverage or term was misrepresented.

Sure, you made the deal. But is it really worth putting the reputation that you have worked years to build at risk? Take compliance and ethical behavior seriously.  A commitment to honesty and fair dealing will protect your company, your employees, your customers and, most importantly, your good name.

There are a number of good reasons for operating an ethical and legally compliant dealership, not the least of which is staying out of a courtroom.  Perhaps the most important - and most often overlooked - reason is increased customer satisfaction.  There are times when an employee may feel that he or she came out the winner by bending the rules a little, but what about the dealership’s reputation?  What about the customers who were mislead?  It seems like there might be some losers in the game.

Customers often make decisions during a vehicle sale transaction that they come to regret after the “ether has worn off”.  Perhaps they read the contract more carefully after they got home or showed it to a relative, friend, neighbor, etc.  The customer may notice some imperfections on the vehicle in the light of day and have it inspected by a mechanic or body shop or run a vehicle history report.  If there is a concern, some customers will let the dealer know while others will just chalk it up to (bad) experience.

Now, if the dealer is lucky enough to get a chance to rectify the customer’s concern, how will the complaint be handled?  Will it be “Sorry, all sales are final” or “You signed the contract”?

What about the customer that doesn’t bother to report the concern?  You can be sure they’re telling somebody about the transaction.  Or perhaps they’re telling thousands of people via social media?

Here are some examples of after-sale situations that can cause potential customer satisfaction nightmares:

• The customer sees your advertisement for a price lower than was charged for the vehicle.
• The customer discovers additional charges on the contract for items that he or she thought were included in the price of the vehicle.
• The customer discovers that F&I products were sold at much-higher-than-market prices.
• The customer discovers additional charges on the contract for items that he or she never agreed to purchase.
• The customer gets a call from the lender who asks for verification that the vehicle has a sunroof – and it doesn’t.
• The customer discovers that the price of the vehicle was raised to cover negative equity on the trade-in when after being told that the dealer agreed to purchase the trade-in for the full loan balance.
• The customer gets a call from the lender asking for verification of an income amount which is much higher than what was written on the credit application.
• The customer discovers that the vehicle purchased had undisclosed prior damage.
• The customer runs a vehicle history report and discovers that the vehicle purchased was an undisclosed previous rental, a prior demo, flood damaged, etc.
• The customer brings the vehicle in for repairs and discovers that the warranty or service contract coverage or term was misrepresented.

Sure, you made the deal. But is it really worth putting the reputation that you have worked years to build at risk? Take compliance and ethical behavior seriously.  A commitment to honesty and fair dealing will protect your company, your employees, your customers and, most importantly, your good name.

A recently filed lawsuit against an auto dealership accused a sales manager of sexual harassment and sexual battery against a salesperson. According to the complaint, the employee was harassed continuously over a ten day period and ultimately quit due to the alleged behavior.  The complaint further stated that the dealership should have known what was going on and tried to correct it.

The dealership responded that the claims have no merit, that it has a zero-tolerance harassment policy and that human resources was not contacted about the situation, as its employee handbook specifies.

I have no idea what the true merits of this particular case are, but it brings to mind what an uphill battle fighting these claims can be.

In some cases, employers may be considered to be “strictly liable” for sexual harassment, meaning that the employer is liable for harassment by an employee or other individual even if the employer did not know about the harassment or acted immediately to stop it. Fortunately, the Supreme Court has recognized a viable defense to this liability. If an employer can prove that it exercised reasonable care to prevent and promptly correct any sexually harassing behavior and the complaining employee unreasonably failed to take advantage of any preventative or corrective opportunities the employer provided or to otherwise avoid harm, the employer may avoid liability for unlawful harassment. Note however, where a supervisor’s harassment includes a tangible employment action (for example, firing the individual); this defense may not be used. An employer is always liable for harassment by a supervisor on a prohibited basis that culminates in a tangible employment action. The Supreme Court recognized that this result is appropriate because an employer acts through its supervisors, and a supervisor's undertaking of a tangible employment action constitutes an act of the employer.

The result in the this case may well come down to whether or not the court believes that the employer exercised “reasonable care” and that the employee “unreasonably” failed to take advantage of opportunities that the employer provided.

Most dealerships have an anti-harassment policy in place that they have all of their employees sign. That’s a great first step, but the questions remain: Have the employees actually read the policy and do they really understand it? Are they really aware of the procedures set forth in the policy to protect them from harassment?

If employees are trained on exactly what to do in the case of harassment (like who to report it to, and so forth) and fail to do so, the dealer will likely be in a better position to defend itself against a claim. On the other hand, if victims of harassment are uncertain about whom to report the harassment to within the company or worse yet, their claims are not taken seriously; they may feel their only recourse is to contact an attorney. That’s when it gets ugly.

The following procedures can be helpful in demonstrating that an employer has taken reasonable care in preventing or mitigating harassment:

• Preparing and adopting an anti-harassment policy and communicating the anti-harassment policies to all employees.
• Clearly communicating that harassment will not be tolerated and clearly explaining prohibited conduct.
• Creating a sexual harassment complaint procedure and explaining the employee’s obligation to report any conduct that may be viewed as harassing.
• Providing every employee with a copy of the harassment policy and complaint procedure, and redistributing it periodically.  The policy and complaint procedure should be written in a way that will be understood by all employees in the employer's workforce.
• Making the anti-harassment policy easily accessible via the company intranet, posters, employee handbooks and including it in the new-hire process.
• Providing sexual harassment training to all employees to ensure that they understand their rights and responsibilities.
• Taking any claim seriously and investigating it.
• Taking prompt and appropriate action.

Unfortunately, being a traditionally male-dominated industry, harassment claims against auto dealerships are not an uncommon occurrence. Having a policy in place and hanging posters may not be enough to adequately protect yourself.

A recently filed lawsuit against an auto dealership accused a sales manager of sexual harassment and sexual battery against a salesperson. According to the complaint, the employee was harassed continuously over a ten day period and ultimately quit due to the alleged behavior.  The complaint further stated that the dealership should have known what was going on and tried to correct it.

The dealership responded that the claims have no merit, that it has a zero-tolerance harassment policy and that human resources was not contacted about the situation, as its employee handbook specifies.

I have no idea what the true merits of this particular case are, but it brings to mind what an uphill battle fighting these claims can be.

In some cases, employers may be considered to be “strictly liable” for sexual harassment, meaning that the employer is liable for harassment by an employee or other individual even if the employer did not know about the harassment or acted immediately to stop it. Fortunately, the Supreme Court has recognized a viable defense to this liability. If an employer can prove that it exercised reasonable care to prevent and promptly correct any sexually harassing behavior and the complaining employee unreasonably failed to take advantage of any preventative or corrective opportunities the employer provided or to otherwise avoid harm, the employer may avoid liability for unlawful harassment. Note however, where a supervisor’s harassment includes a tangible employment action (for example, firing the individual); this defense may not be used. An employer is always liable for harassment by a supervisor on a prohibited basis that culminates in a tangible employment action. The Supreme Court recognized that this result is appropriate because an employer acts through its supervisors, and a supervisor's undertaking of a tangible employment action constitutes an act of the employer.

The result in the this case may well come down to whether or not the court believes that the employer exercised “reasonable care” and that the employee “unreasonably” failed to take advantage of opportunities that the employer provided.

Most dealerships have an anti-harassment policy in place that they have all of their employees sign. That’s a great first step, but the questions remain: Have the employees actually read the policy and do they really understand it? Are they really aware of the procedures set forth in the policy to protect them from harassment?

If employees are trained on exactly what to do in the case of harassment (like who to report it to, and so forth) and fail to do so, the dealer will likely be in a better position to defend itself against a claim. On the other hand, if victims of harassment are uncertain about whom to report the harassment to within the company or worse yet, their claims are not taken seriously; they may feel their only recourse is to contact an attorney. That’s when it gets ugly.

The following procedures can be helpful in demonstrating that an employer has taken reasonable care in preventing or mitigating harassment:

• Preparing and adopting an anti-harassment policy and communicating the anti-harassment policies to all employees.
• Clearly communicating that harassment will not be tolerated and clearly explaining prohibited conduct.
• Creating a sexual harassment complaint procedure and explaining the employee’s obligation to report any conduct that may be viewed as harassing.
• Providing every employee with a copy of the harassment policy and complaint procedure, and redistributing it periodically.  The policy and complaint procedure should be written in a way that will be understood by all employees in the employer's workforce.
• Making the anti-harassment policy easily accessible via the company intranet, posters, employee handbooks and including it in the new-hire process.
• Providing sexual harassment training to all employees to ensure that they understand their rights and responsibilities.
• Taking any claim seriously and investigating it.
• Taking prompt and appropriate action.

Unfortunately, being a traditionally male-dominated industry, harassment claims against auto dealerships are not an uncommon occurrence. Having a policy in place and hanging posters may not be enough to adequately protect yourself.

Employee training can cost a lot of money. Not training your employees can cost even more. In lawsuits, courts and regulatory agencies sometimes impose after-the-fact training requirements in addition to large monetary penalties. Consider these actual cases:

A dealership faced a wide range of complaints, including failure to disclose material defects and misrepresenting sales and extended service contract prices, and was ordered to pay $1.5 million in restitution to victims, plus $300,000 to the state Department of Consumer Protection. As part of the settlement, the dealer also agreed to initiate a mandatory education program for all its employees within 60 days of the settlement, instructing employees on state consumer protection laws.

A jury awarded a $14.4 million wrongful death verdict against a dealership that performed a faulty tire repair and failed to take the tire out of service, leading to a rollover crash that killed a couple. As a condition of the post-verdict settlement, the dealer agreed to implement a training program to better train its technicians about safe tire repair practices to improve consumer safety.

The Equal Employment Opportunity Commission (EEOC), entered into a $1.5 million settlement of a sex and age discrimination lawsuit with an auto dealership. Along with the monetary penalty, under a consent decree the dealership must provide current employees with four hours of EEO training annually and new hires must receive such training within ten days of employment.

The EEOC reached a $700,000 settlement of a national origin, religion and racial discrimination lawsuit against another dealership. According to the Consent Decree resolving the case, the dealership is required to hire a presenter approved by the EEOC to provide annual training to all of its managers and supervisory personnel on all aspects of Title VII.

What’s that old expression about closing the barn door after the horses are out?

Employee training can cost a lot of money. Not training your employees can cost even more. In lawsuits, courts and regulatory agencies sometimes impose after-the-fact training requirements in addition to large monetary penalties. Consider these actual cases:

A dealership faced a wide range of complaints, including failure to disclose material defects and misrepresenting sales and extended service contract prices, and was ordered to pay $1.5 million in restitution to victims, plus $300,000 to the state Department of Consumer Protection. As part of the settlement, the dealer also agreed to initiate a mandatory education program for all its employees within 60 days of the settlement, instructing employees on state consumer protection laws.

A jury awarded a $14.4 million wrongful death verdict against a dealership that performed a faulty tire repair and failed to take the tire out of service, leading to a rollover crash that killed a couple. As a condition of the post-verdict settlement, the dealer agreed to implement a training program to better train its technicians about safe tire repair practices to improve consumer safety.

The Equal Employment Opportunity Commission (EEOC), entered into a $1.5 million settlement of a sex and age discrimination lawsuit with an auto dealership. Along with the monetary penalty, under a consent decree the dealership must provide current employees with four hours of EEO training annually and new hires must receive such training within ten days of employment.

The EEOC reached a $700,000 settlement of a national origin, religion and racial discrimination lawsuit against another dealership. According to the Consent Decree resolving the case, the dealership is required to hire a presenter approved by the EEOC to provide annual training to all of its managers and supervisory personnel on all aspects of Title VII.

What’s that old expression about closing the barn door after the horses are out?

As I read through dealer websites, I’m often surprised at how many advertising violations I find. You would think that website providers would make sure that this doesn’t occur, right?

You should never assume that the company that creates and maintains your website follows all the laws and regulations governing advertising compliance. State advertising laws vary and the responsibility for compliance lies with the dealership, not the vendor. Here are some examples of what I’ve run into and issues to look for:

• Disclaimers - Website providers sometimes include boilerplate factory disclaimers on inventory pages that identify vehicles by a specific VIN and price, such as:
  • “Advertised vehicles are subject to actual dealer availability. Certain vehicles listed may not be available, or may have different prices.”
  • “Pricing and availability varies by dealership.”
  • “Prices do not include dealer charges, such as advertising, that can vary by manufacturer or region, or costs for selling, preparing, displaying or financing the vehicle.”
  • “Images displayed may not be representative of the actual trim level of the vehicle.”
  • “Information provided is believed to be accurate but all specifications, pricing and availability must be confirmed in writing (directly) with the dealer to be binding.”

While these types of disclaimers may be appropriate when advertising a model line, they probably shouldn’t be associated with specific vehicles. Advertised vehicles that are identified by VIN are subject to prior sale, but they certainly should not be subject to “different prices”. You should also determine which charges are allowed to be excluded from an advertised price in your state.

• Check to determine if all necessary disclosures are present on your site. For example, “advertised prices exclude tax, government fees, etc.” Again, do not assume that your website provider is utilizing language that is acceptable in your particular state or including all of the required disclosures.
• Be sure that all disclaimers are clearly and conspicuously displayed and not buried away in a difficult-to-find link elsewhere on the site.
• If payments, downpayments or interest rates are advertised, make sure that all of the proper Truth in Lending and state disclosures are included.
• Ensure that lease programs are properly disclosed. Many factory national lease programs contain generic information that may not be sufficient or appropriate in your state.
• Some states require that vehicle history, such as prior rental or demonstrator, is disclosed on vehicle advertisements. Does your website provide a way to include these disclosures?
• Ensure that vehicles are promptly removed from the website after they have been sold. Some sites are linked to the dealer’s DMS and will remove sold units automatically, while others require vehicles to be removed manually. Sold units should always be removed promptly to avoid potential bait and switch advertising claims.

It’s never a bad idea to have your website thoroughly reviewed by a compliance professional. Remember, advertising violations can be easy for regulators to spot and difficult to defend against.

As I read through dealer websites, I’m often surprised at how many advertising violations I find. You would think that website providers would make sure that this doesn’t occur, right?

You should never assume that the company that creates and maintains your website follows all the laws and regulations governing advertising compliance. State advertising laws vary and the responsibility for compliance lies with the dealership, not the vendor. Here are some examples of what I’ve run into and issues to look for:

• Disclaimers - Website providers sometimes include boilerplate factory disclaimers on inventory pages that identify vehicles by a specific VIN and price, such as:
  • “Advertised vehicles are subject to actual dealer availability. Certain vehicles listed may not be available, or may have different prices.”
  • “Pricing and availability varies by dealership.”
  • “Prices do not include dealer charges, such as advertising, that can vary by manufacturer or region, or costs for selling, preparing, displaying or financing the vehicle.”
  • “Images displayed may not be representative of the actual trim level of the vehicle.”
  • “Information provided is believed to be accurate but all specifications, pricing and availability must be confirmed in writing (directly) with the dealer to be binding.”

While these types of disclaimers may be appropriate when advertising a model line, they probably shouldn’t be associated with specific vehicles. Advertised vehicles that are identified by VIN are subject to prior sale, but they certainly should not be subject to “different prices”. You should also determine which charges are allowed to be excluded from an advertised price in your state.

• Check to determine if all necessary disclosures are present on your site. For example, “advertised prices exclude tax, government fees, etc.” Again, do not assume that your website provider is utilizing language that is acceptable in your particular state or including all of the required disclosures.
• Be sure that all disclaimers are clearly and conspicuously displayed and not buried away in a difficult-to-find link elsewhere on the site.
• If payments, downpayments or interest rates are advertised, make sure that all of the proper Truth in Lending and state disclosures are included.
• Ensure that lease programs are properly disclosed. Many factory national lease programs contain generic information that may not be sufficient or appropriate in your state.
• Some states require that vehicle history, such as prior rental or demonstrator, is disclosed on vehicle advertisements. Does your website provide a way to include these disclosures?
• Ensure that vehicles are promptly removed from the website after they have been sold. Some sites are linked to the dealer’s DMS and will remove sold units automatically, while others require vehicles to be removed manually. Sold units should always be removed promptly to avoid potential bait and switch advertising claims.

It’s never a bad idea to have your website thoroughly reviewed by a compliance professional. Remember, advertising violations can be easy for regulators to spot and difficult to defend against.

Before the internet, when there were only phone pops, we learned valuable lessons on how to handle calls, such as selling the appointment, creating urgency, not giving shopping numbers and keeping information close to the vest until the customer showed up. It was good advice then and it may be good advice now. But keep in mind that many customer inquiries tend to come online rather then by phone. While the ultimate goal remains the same – to get the customer into the dealership – the rules for execution have become trickier because online communication creates a permanent written record of all interactions with customers.

In addition, many dealers are now utilizing social media as an easy and affordable way to promote their products and services. It’s important to understand that even though it may not require writing a big check, certain social media postings may be considered advertising and proper care should be taken to avoid legal exposure. As we are painfully aware, there are plenty of federal and state regulations that govern automotive advertising. For instance, social media postings that list vehicle prices, payments, downpayments or drive-off amounts may trigger advertising disclosure requirements.

Here’s an illustration of how an online interaction could potentially come back to haunt you. A few days before this past Labor Day, I saw a posting from a dealer on their Facebook page about a Labor Day weekend special that offered zero drive-off leases. During this time period, several competing dealers ran newspaper advertising on similar lease programs with “no money down, zero driveoff, leave your checkbook at home” and so forth. On closer inspection, many of these ads indicated in the fine print that certain fees were due at signing, such as tax, license, doc fees and acquisition fees.

I logged on to the Facebook dealer’s website to check out the actual ad (there were no disclosures on the Facebook posting other than zero drive off). The ad indicated that the customer was responsible for tax and license. I then contacted the dealer online to inquire whether I had to pay for the tax & license or if it was indeed “zero out of pocket”. The dealer representative responded that yes it was zero down, but since it was the last day of the month, I needed to come in before close of business to take advantage of the special lease.

Now, let’s look at some possible outcomes if a customer decided to go to the dealership that night.

If the customer went to the dealer to lease the car and there was indeed no money down required and they gave her the advertised payment, she would probably leave happy and nothing else would matter.

But, if she showed up at the dealership and they informed her that she had to pay other fees to get the advertised payment, a few other things might happen:

1. She might reluctantly pay the fees or roll them into a higher payment. The salesperson’s closing ratio would go up and his CSI would go down.
2. She might leave and go lease a car from another dealer.
3. She might decide to take the written evidence of the transaction to her friendly neighborhood attorney. This could happen the next day or sometime in the future if she decides that she no longer wants the car.

Here are some potential claims that an attorney might make. First, I wouldn’t be surprised if an aggressive attorney would try to make a case for Unfair and Deceptive Acts and Practices (UDAP) for the dealer rep’s little miscommunication about zero down (remember, the customer has an email from the rep that said there was no money required).

Next, the dealer’s Facebook posting stated that they were having a “Labor Day Weekend” sale, yet the dealer rep claimed (in writing) that the sale was over the Tuesday BEFORE the Labor Day weekend. Another deceptive act?

The attorney might also throw in a few advertising violation claims for good measure, such as that the Facebook posting may have lacked some required advertising disclosures and the disclaimer in the dealer’s website may not have been clear and conspicuous enough to be in compliance.

There’s a good chance that an aggressive lawyer would throw all of those nitpicky claims against the courthouse wall to see what sticks. Plaintiff’s attorneys love UDAPs, they can often get multiple damages and attorney fees if successful.

So, here’s my two cents: Be careful what you say; even more careful what you write and if you communicate with customers, it’s not a bad idea to get some training in legal compliance.

Before the internet, when there were only phone pops, we learned valuable lessons on how to handle calls, such as selling the appointment, creating urgency, not giving shopping numbers and keeping information close to the vest until the customer showed up. It was good advice then and it may be good advice now. But keep in mind that many customer inquiries tend to come online rather then by phone. While the ultimate goal remains the same – to get the customer into the dealership – the rules for execution have become trickier because online communication creates a permanent written record of all interactions with customers.

In addition, many dealers are now utilizing social media as an easy and affordable way to promote their products and services. It’s important to understand that even though it may not require writing a big check, certain social media postings may be considered advertising and proper care should be taken to avoid legal exposure. As we are painfully aware, there are plenty of federal and state regulations that govern automotive advertising. For instance, social media postings that list vehicle prices, payments, downpayments or drive-off amounts may trigger advertising disclosure requirements.

Here’s an illustration of how an online interaction could potentially come back to haunt you. A few days before this past Labor Day, I saw a posting from a dealer on their Facebook page about a Labor Day weekend special that offered zero drive-off leases. During this time period, several competing dealers ran newspaper advertising on similar lease programs with “no money down, zero driveoff, leave your checkbook at home” and so forth. On closer inspection, many of these ads indicated in the fine print that certain fees were due at signing, such as tax, license, doc fees and acquisition fees.

I logged on to the Facebook dealer’s website to check out the actual ad (there were no disclosures on the Facebook posting other than zero drive off). The ad indicated that the customer was responsible for tax and license. I then contacted the dealer online to inquire whether I had to pay for the tax & license or if it was indeed “zero out of pocket”. The dealer representative responded that yes it was zero down, but since it was the last day of the month, I needed to come in before close of business to take advantage of the special lease.

Now, let’s look at some possible outcomes if a customer decided to go to the dealership that night.

If the customer went to the dealer to lease the car and there was indeed no money down required and they gave her the advertised payment, she would probably leave happy and nothing else would matter.

But, if she showed up at the dealership and they informed her that she had to pay other fees to get the advertised payment, a few other things might happen:

1. She might reluctantly pay the fees or roll them into a higher payment. The salesperson’s closing ratio would go up and his CSI would go down.
2. She might leave and go lease a car from another dealer.
3. She might decide to take the written evidence of the transaction to her friendly neighborhood attorney. This could happen the next day or sometime in the future if she decides that she no longer wants the car.

Here are some potential claims that an attorney might make. First, I wouldn’t be surprised if an aggressive attorney would try to make a case for Unfair and Deceptive Acts and Practices (UDAP) for the dealer rep’s little miscommunication about zero down (remember, the customer has an email from the rep that said there was no money required).

Next, the dealer’s Facebook posting stated that they were having a “Labor Day Weekend” sale, yet the dealer rep claimed (in writing) that the sale was over the Tuesday BEFORE the Labor Day weekend. Another deceptive act?

The attorney might also throw in a few advertising violation claims for good measure, such as that the Facebook posting may have lacked some required advertising disclosures and the disclaimer in the dealer’s website may not have been clear and conspicuous enough to be in compliance.

There’s a good chance that an aggressive lawyer would throw all of those nitpicky claims against the courthouse wall to see what sticks. Plaintiff’s attorneys love UDAPs, they can often get multiple damages and attorney fees if successful.

So, here’s my two cents: Be careful what you say; even more careful what you write and if you communicate with customers, it’s not a bad idea to get some training in legal compliance.