Managerial Compliance & Responsibilities

Compliance as a Manager

• Managers have specific responsibilities regarding company compliance
• Requires reading the handbook
• Compliance with Gillman's policies and all state and federal laws is expected

Open-Door Policy

• Gillman Companies has an open-door policy
• There is an invitation to come talk to any manager at any time about anything

Reporting Concerns

• Problems and concerns should first be reported to the direct supervisor or General Manager
• This provides an opportunity to correct the situation
• The Human Resources Office can be contacted at 713-776-7062 with problems or questions
• There is an invitation to contact the executive offices to voice areas that require attention
• Incidents should be reported timely and be solution-oriented

Sales/Success Manager Responsibilities (Effective 01/01/2024, Last Revised 01/01/2024)

• Success Managers are responsible for following Gillman Companies sales processes
• The success of assigned sales personnel is the Success Manager's responsibility
• This includes maintaining open communication, holding one-on-one meetings, and ensuring adequate training
• Continuously develop and train sales personnel
• Maintain proper staffing levels
• Hiring procedures outlined in Policy No. 8 should be followed
• Personnel Change Notices (PCNs) and Separation forms must be completed and submitted to the Payroll Department in a timely fashion
• PCNs must be submitted a day before the new hire's orientation date
• Separation forms must be submitted within 24 hours of the employee's separation
• Report of All Losses form should be appropriately completed and promptly presented to Gail Caffey in the event of accidents involving employees, customers, or company-owned vehicles
• For injured employees, attend to the employee, contact Jody Valentine in Human Resources, and send the employee to a designated clinic
• Complete and email the First Report of Injury form to Jody Valentine immediately, copying the General Manager and Patrick York
• Gillman employees involved in accidents must undergo a drug test ASAP
• Maintain a clean and professional work environment
• Hold new department employees accountable for the appearance of sales departments
• SPIFF programs are encouraged but require approval from the General Manager and oversight review from the Gillman Executive Office
• Customer personal information must be properly safeguarded with routine supervision
• Each dealership facility must have a centralized designated locked storage area where dead deal files are stored

Dead Deal Storage

• Dead deal files are to be stored pending the accounting office taking possession
• Dead deals are to be turned into accounting in a timely manner in accordance with company policy
• The period should be no less than once weekly
• Gillman Companies must comply with record-keeping guidelines and Adverse Action rules

Sales Manager Responsibilities

• Identify and adequately note any documents that misrepresent facts relating to the application or the sale
• No customer information is to be adjusted, altered, or in any way changed by a sales manager
• Falsified information may never be submitted to a lender
• Be mindful and vigilant for any and all possible fraud
• All handwritten customer credit applications must be kept in the customer deal file and not discarded, no exceptions
• Sales Managers must verify the mileage on all trade-ins to prevent issues when selling the vehicle
• Gillman is not able to register vehicles until we get the corrected mileage
• Ensure all down payment funds (significantly cash) are properly receipted and deposited according to company policy
• Handwritten receipts are prohibited
• Down payments utilized on Special Finance deals must be submitted in certified funds

Procedures for Deliveries

• All deliveries must have a Retail Installment Contract or a Conditional Delivery Agreement processed by Financing and Insurance(F & I) only
• Sales Managers do not have the authority to submit deals to lenders
• All deals should be submitted by F & I and/or General Managers
• Third-party checks are not to be accepted on any deals
• Third-party trades require supporting written disclosure from the record owner agreeing to the vehicle's use, and handwritten and signed authorization with video footage
• A straw purchase is if person (A) buys a car for and on behalf of person (B), and there is no family relation between them
• In the event of valid information indicating that a deal is a straw purchase, communicate that information to your GM before the deal goes any further
• The Dealer Track system should be fully utilized to ensure complete compliance with Red Flag Rules

Delivery Requirements

• No dealership vehicle will be delivered to any customer unless the dealership computer system has been updated to reflect the delivery transaction
• This includes driver's license, insurance, and the specific stock number of the vehicle
• In addition, a Gillman F&I Manager must have the opportunity to meet with the customer BEFORE they leave
• There should be a record of all vehicles in the POWER system
• Retail Delivery Records ("RDR's") should be limited to car deals in which the vehicle has been delivered and contracted
• Alterations to customer information are a violation of policy, subject to termination
• RDRs should be transmitted by the Sales Secretary assigned to the dealership
• Sales Managers are not allowed to punch RDRs, except after hours on the last day of the month, in which case the RDRs will be double-checked

Financial Processes

• Sales Managers are responsible for following up and clearing up any balances due to Gillman as a result of dealer trades
• Sales Managers are not authorized to sign advertising and Gross Evaporation agreements or contracts with vendors
• Do not over-promise or under-deliver with respect to refunds, referrals, or payoff differences
• Differences are not released until clear title, referrals are not paid until deal billing, and refunds take longer

Sales managers are not permitted to

• Do business with a wholesaler unless approved by the executive offices
• Any infraction of this policy will be subject to disciplinary action up to and including termination of employment
• Contact a lender regarding a callback or rehash; only GMs and Finance Managers may
• The exception is to obtain pay-off information
• Any vehicle sitting on Gillman premises for longer than two weeks that is not owned by Gillman must be reported to the General Manager
• All cash deals must have credit pulled on the buyer writing the check, unless certified funds are provided
• Verifiable insurance is required

Business sales cash deals

• Require a corporate resolution authorizing purchase
• Credit must be pulled on the person writing the check
• If credit cannot be pulled, certified funds must be used
• Special Finance deals require certified funds and all bank-required stipulations must be in house
• The vehicle must be added to verifiable full coverage insurance before leaving Gillman property
• Purchases of multiple vehicles requires notification and approval from the Executive Office
• Used car transactions where the bank requires a book out, must be correctly represented with all optional/deducted equipment.
• Misrepresentation is subject to disciplinary action up to termination

F&I and temporary tags

• Temporary tags should only be issued at the point of sale/delivery
• If it expires, promptly notify the Controller for a second tag through the courthouse
• Failure to notify the controller results in disciplinary action up to termination

F&I Manager Responsibilities

• Adhere to the highest ethical standards in finance and insurance management
• This role is vital to maintaining compliance, trust, and profitability in the dealership
• Managers must perform the following to the best of their ability: ensuring accuracy, disclosing every charge, understanding customer questions, video disclosures, submitting matching contracts, and processing two e-menus

Accuracy is Key

• The F&I Manager must review and confirm the accuracy of both the customer's handwritten credit application and the dealer track application, ensuring consistency with the Buyer's Order, especially regarding personal information
• Any material alterations must have a factual basis and require lender notification before submission for funding

Disclosures and Compliance

• Fully disclose every charge on the Retail Installment Contract, complying with TILA Regulation Z
• Ensure customers read and understand the Statement of Insurability on credit life & disability applications
• Create Gillman Video Disclosures for all transactions and include in every file, waiving is prohibited
• Execute calls back and rehashes in the exact manner of the lender

Processes needed during F&I

• Match final contract submission to the approval
• Every deal must be processed through F&I with two e-menus signed by the customer
• It will be signed off by the General Manager
• A “quote” deal turned real vehicle may be returned to "quote" status
• Real delivery will be converted, with no back/future-dating
• Every real car deal must have either the Gillman F&I Manager or the General Manager submit it to lenders.

Lender Honesty

• The submitted deal must be truthful
• No misrepresented/false facts
• The account must always inform other places multiple customers buy from, to ensure no one else gets a deal for themselves at the same time

Credit and vehicle

• No third parties
• No straw purchases
• Proof must include a license, income, liability insurance
• In addition, comp and collision insurance requires unit verification by VIN
• Expirations must be more than four months away • No signed forging of any document on customer's behalf, which is never allowed

Products to use

• Always present all of the products to the customers
• Strict adherence to 100% compliance and 100% disclosure
• When a customer opts to forego any benefit, use color-coded declination pages

If ever finding forgery or altered documents/ things against a company's policy...

• Alert the management
• Also re-explain benefits if a customer backs out
• Submit a cancellation
• Only let a customer sign one contract at a time
• Never both Installment Contract, and Delivery Agreement

F&I best practices

• Safeguard any F&I office during private matters
• Computers must have a password
• Dealerships cannot be taken anywhere

Others to be aware of

• Third-party authorizations
• Payments only with certified funds ( special deals)
• The red flags in the Dealer Track system should be used to their potential
• Customers without identity cannot be sold to.
• Accountings should move in a timely manner.
• Finally risk-based scoring notifications must be given as they should.

Other people to collaborate with finance managers

• Only work with people approved by the Chief Operating Officer (Patrick York)

Limits on all

• Checks
• The General; -Contacting lenders ( except for sales that need pay info)
  • Letting other vehicles take up room ( over 2 weeks without Gillman)
  • Cash deals must pull credit

Under no circumstance are discrimination and other violations allowed.

• Finally, Executive and finance roles must only work to their potential to avoid any more employee problems.

Sales Processes Policy 3

• Describes the responsibilities and expectations for Sales/Success Managers within the Gillman Automotive Group, emphasizing training, customer interaction, and prospecting
• effective from January 1, 2022, last revised at the same date
• The goal, to provide structure to employees and active leadership from management

Training Requirements

• The company must adopt training, along with certification programming from a lot of sectors
• The course, in addition, must prepare managers to handle management staff and fundamentals efficiently

Training Goals

• Greeting- verbal questions
• Needs analysis- finding out what the customer knows
• Vehicle Review - walk around silently
• Vehicle Selection avoid dead batteres
• Presentation- what it has
• What a product has, like Window Tint or Tires

Demonstration

• Make sure a customer is satisfied with where they drive
• Dealership tour- tour the service
• Customer agreement- acknowledge any problems
• Working with Customer with confidence Business Office: going into the offer delivery

Prospect Guidelines

• Prospect, don't sell yourself like a car
• Sales Managers should provide weekly production training
• Staff to ensure that everyone does well
• Refer all clients back here

How can we improve communication?

• Respond via leads,
• Make aware,
• Finally, keep in mind you can't sell when the lot is low

In what respect did the company set a "limit" on things?

• Limit to trades

To reduce expenses, the steps are to check the potential for a customer's "aging of a unit.

Monthly Volume and Gross Expectations

• Describes the process for setting monthly volume and gross expectations for Sales Managers. It emphasizes achieving goals and reviewing performance

ELead Sales Manager

• The report is done daily
• Updated every 10 days by the General Manager
• Finally have a meeting.

Gillman Companies Minimum F&I PRU Standard (Policy 5)

• Establishes a minimum monthly standard for F&I Managers, aiming to remain employed
• If, when or if employees are beyond for over 90 days with the F&I, then remain employed.
• Any failure to meet means having a 30-day warning
• After failure to meet once or twice, there cannot be a rehiring for over 30 days.
• The minimum F&I is over 1500 dollars.

Sales Achievement Program 6

• Make certain their salespeople at a store get the opportunity
• Support and train them for an excellent topic and also help managers
• The two points are units and the overall average

Certification program overview

• Gillman's attempt to increase satisfaction and reduce interruption
• This will improve success and training
• A condition of employment
• Classes must be done in 18 months

Management Class requirements

• Every meeting is over 1000 per class/5 total classes to reserve a full fund
• The paycheck is 225, but all 5 classes must be fulfilled.
• More classes equals earning degrees.
• The group pays .555 mile, meal and a night

To have a waiver

• Requires Stacey Gilliams and the like

What if the undergraduate failed to graduate yet?

• If this undergraduate is rehired, he'll start where he left off. General Comp and sales Comp no. 8 Commissions and bonus (pay plan) will have management fees. ( To have admin fee.) A person should overview their comp with dealership controller. ( If not satisfied.)

As management, rights include investment in a given Company's cash management account

Manufacturer payment details:

-Floorplan assistance is one of the many payments

• Holdback recorded

• The items will not be taken without the EO's approval

Ethics Policy

• Requires reporting suspicious violations of ethics

• Do not allow a problem

• -- If unethical contact Richard Woer

• -- What applies in lending companies is the "truth"

• -Do not alter anything, keep secrets

• -- The EOM checklist shows that Stacey likes conditions good

The end goal in action: support all conditions.

Service Operations: (9, 10, 11)

• --Ethics: warranty fraud and similar (report it) --Service 42 days given the ability to satisfy employees
• --Make sure the employees have an update
• --Be wary of the used car industry
• --Training provided

General:

• collection should be 80 percent
• The goals should never break.
• Decline and approve is around 20%

The 12 step:

• Dept/Store marketing should be with both parties Employees should keep up " behavior"

Gray market parts substitutions and other substitutions:

• Should not occur.

Fixed Operations other parts:

• 14 requires tracking of inventory

• 14 needs reconcilarion

• A. Manager should know everything

• B. managers review the invoice The sales should review accounts. Core credits

Fix that policy: 15

• The sales should be good, days good, " gross to sale" good

17:

• Richard will run things, not other. Back people Be prepared. Inspect, make it easier on people, train people Make sure people don't get " bad "

New hire procedures(19 in the Houston and 19-10)

A: Follow the steps to help hiring winners (talents)

All managers do the 12 step process. If not up there, we don't give them numbers. C: Log in for those steps and give candidate details!

• Send via mail

• If all good, report to HR

• The end part is signatures

Under the right to hire, a social account is involved

• With the correct, necessary credentials of paperwork

• A background check or others, will be called in at Cole Group, with HR getting it approved.

• When through orientation, an employee gives what is required.

• Passwords get people rolling

• It's better to have new people give the info immediately. I19/The hiring process works Manager's Policy Regarding Applicant Drug Screens (number has to do everything with what's new: 20)

A1: People who have to get new roles need some attention, but some require "a new test. If yes they must be terminated to be ready or be legal. It goes through personnel The applicant has " drug screen results "

Rejection Policy 21

1. What is, or how do managers reject an applicant? You can never commit. Just imply that " you're applying among many other people."

• --A. Follow a " no" rule to handle lawsuits

B. 22, Loss. All must be good at controlling our losses. You can lose something by missing, with HR determining what to do

C. 23, Must always attend the safety meetings via CFO, or else face high payments in a deduction.

24 : "Medical centers" is only specific for " the one that needs it."

Adverting :

25 A) Must follow company's adverting to get maximum B) Get those things and the following together. C) You're not to ad contract or overdo payments or change the advertising itself to pay.

Lost Key :

Policy 27 is to charge each day for the fob.

The last steps for what's lost!

Report what's lose Get statements

• --There are some things that can't be said."Insurance data
• -Accedientsite's.

The next step involves

• Calling that person/emailing that person

52. In injury cases give them what's described, call people.

530 Have it handled

Finally, here's: all for the ""Employee Purchase"" 30. and those steps:

• --A - People can buy up 1 year total to be paid for by employees/business

.---Cost has expenses

• --It has conditions, however ( like not causing "money lost," for the front ""All manager, before the signing. the numbers . What must be there for it to qualify What will be approved

Final step : Make sure all comes back from CEO

Final policy (31)

• The time " attendance" policy should be only what is recorded. Be on it."No fudging records"
• Then add all into the correct part"
• --Finally click OK ""

Hot work permit

• A- The permission of hot needs is to work carefully. B- Here are the points :
• Task
• • People and equipment C- Know this - it has sprinklers" D- It won't have gasses or liquids." It has blankets D- Do not keep combustibles, open floors, or conveyors." E---What can cause this? Shut doors, put some fire. "" 4 The issuer needs to come sign. Get people out"" F: Be sure to call a "fire watch" people There can always be danger. Be sure all are safe or protected by blanket with materials. The end part = It will stay near the fire alarms/the person issuer for over year Finally all 37 steps !