LAS VEGAS — Dealers feverishly took notes in a packed
conference room on Tuesday as a quartet of legal experts shared compliance
procedures these owners and managers can immediately put into place upon
returning to their stores after the National Alliance of Buy-Here, Pay-Here
Dealers National Conference.

In a regulatory world intensifying thanks to the arrival of
the Consumer Financial Protection Bureau, dealers especially took notice of a
comment made by Hudson Cook chairman Tom Hudson.

"The bureau simply doesn't care if they put a dealer out of
business," Hudson told the attendees at the Wynn in Las Vegas.

Hudson Cook partner Patty Covington also participated in the
conference's opening session with Steve Levine of AutoStar Solutions and Terry
O'Loughlin of Reynolds and Reynolds.

Among some of the points this group raised during a panel
presentation titled, "Compliance Moves to Make Now," the legal practitioners
mentioned:

—Establish a formal plan to monitor a store's relationships
with third-party vendors and put someone in charge of executing that plan.

—Verify that the dealership's third-party service providers
understand and comply with law applicable to the store's business

—Conduct a thorough analysis of the dealership's insurance
coverage as a part of an overall risk assessment, and review insurance coverage
of third-party vendors.

"You've got to get to know your service providers because
the CFPB mandates it," Levine said. "That's a big deviation from where we've been."

Meanwhile, O'Loughlin described state attorneys general as
the "foot soldiers of the CFPB." O'Loughlin can speak from experience since
before he came to Reynolds and Reynolds, he was part of the legal team for the
Florida attorney general's office.

O'Loughlin recommended that BHPH dealers monitor their
advertisements, especially campaigns that include phrases such as, "You work.
You ride."

He added, "The attorneys general love advertising cases
because they're so easy. You don't want to be noticed by your state attorney
general."

For stores that cannot afford to add personnel, Covington
recommended that a certain type of individual already on the payroll could make
for a great candidate to be a compliance officer to maintain policies and
procedures.

"Find the rule follower in your shop," Covington said. "That's
the person who should be your compliance officer.

"I don't want to scare you but you have to have compliance
on your radar because there are more cops on the beat," she went on to say, pointing
out the auto financing regulatory world not only includes the CFPB, but also
the Federal Trade Commission and the Department of Justice.

A lively question-and-answer session followed the remarks by
Hudson, O'Loughlin, Levine and Covington. It set the stage for what NABD
officials believe is one of their best conferences.

Today's sessions include panel presentations about
maximizing recoveries, inventory acquisition, as well as a dealer best
practices panel. Also on the docket is the keynote address by Joe Gibbs, Super
Bowl winning football coach and owner of NASCAR championship teams.

The conference wraps up on Thursday with the newest inductee
to the BHPH Hall of Fame and the unveiling of the industry's benchmarks
prepared by NABD with Subprime Analytics and NCM Associates.

"What dealers will learn during this conference will help
them navigate 2013 more successfully. The profit opportunities have never been
greater when operators make the right decisions," NABD founder Ken Shilson said.

Nick Zulovich can be reached at nzulovich@subprimenews.com. Continue the conversation with SubPrime Auto Finance News on LinkedIn and Twitter.