The IndustryCommentary & Insights

The Industry
Everywhere I look, I see automotive

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Steve Schmith is the director of automotive industry strategy at Acxiom . He has spent nearly all of his 25 years of professional experience working in the automotive industry, including 17 years at Deloitte, wrapping up his tenure as the Global and US Automotive Marketing Leader and two years at Automotive News as the Executive Director of Custom Research and Data and host of the Daily Drive podcast. I caught up with Steve at 7am, as he has his morning coffee and is accompanied by his three Boston Terriers. The Industry of Opportunities “I had no intention of ever working in automotive. In fact, I had never even been to Detroit.” I went to journalism school, I got a degree in journalism with a minor in television and radio production. I actually started my career in economic development. What I have come to love about this industry and what outsiders sometimes don’t see is how much opportunity there is in the automotive industry. If you’re an engineer, a designer, a marketer, if you studied supply chain, I really believe that there is an unrecognized opportunity for folks who didn’t grow up in an automotive family, to create their space here. I think that when most people think about the automotive industry and dealers, they stop with the transaction; the sale of the car. The truth is, when you think about it more broadly, and you think about how people connect with all the brands in their lives, it is so much more than that.  There are so many vendors because there are so many opportunities. From selling a vehicle, to financing a vehicle, insuring, repairing, and servicing, as examples.  If you’re in the business of reconditioning vehicles, or running fleets. And none of that even begins to touch on what happens when you’re inside the vehicle, particularly as vehicle connectivity improves, matures and scales and the opportunities to connect with customers those technologies create. There are just so many opportunities for people to connect with brands and there are increasingly a lot of brands – automakers, suppliers, lenders, insurers, in-vehicle content providers, etc. – competing for that attention.  “I think a lot, I think about the industry a lot.” Clearly these are exciting and fundamentally transformative times in the automotive industry, so it helps being such a fan of the industry, a fan of the brands and the manufacturers. It’s also very fun and inspiring to be on the road and to see these beautiful machines and all the technology. You often hear people speaking about automotive brands as if it forms a part of their identity. These brands are very personal to people. They take them on family trips, they take them to work every day, they hold our families and they are where some of the most wonderful conversations happen. I just feel so lucky to be a part of the automotive industry, to work in storytelling, in strategy, to bring it all together in such a personal way. Being able to relate the personal nature of automotive and the brands in this industry helps as our team at Acxiom thinks about and strategizes how we can best deliver value to our automotive clients. An Industry in Motion “It surprised me that it took a pandemic to really drive digital retailing.” Digital retailing in our industry has been around for 20 years but there was really no catalyst to put a lot of money into it because the model was working. Coming out of the 2009-10 Great Recession, we were on a growth trajectory that did not stop for 10 years.  So, understandably, there was no reason for automakers or their franchised dealers to go “all in” and fully invest in, adopt and scale what is best-in-class digital retailing.  Then suddenly, the pandemic hit and the environment changed. We saw disruptors entering the market who did not require the in-person relationship, and they became very big competitors. It’s amazing to see how far we have come in the last two years and, yes, there is a lot of disruption and, yes, there is a lot of investment and growth but I am truly excited and think it is so wonderful to see how companies are focused on connecting with customers.  An Industry Driven by Data: The Changing Ecosystem “As we push digital, we also need to understand that we have this entire ecosystem of businesses that have historically worked within very defined industry lines. Those lines are blurring.” There are so many opportunities for different brands in the connected mobility business ecosystem to connect with people outside and increasingly inside of the vehicle. There are so many aspects of the full customer journey when you think of the entire experience. Whether they are driving the vehicle, sharing it, or riding in it. Whether they are getting it serviced or charging their EV. The once clear industry lines separating the brands engaging people as they move from one place to another are blurring more and more each day.  On the flip side, having that single view of the customer gets very hard and that is where Acxiom really plays well and creates value for our clients. That is our core competency, our ability to create a single view of the customer and help brands deliver in real-time personalized, omnichannel customer experiences based on a deep understanding of people.  If you consider the buying side, there are multiple channels where a person interested in buying a vehicle can enter the shopping funnel – an automaker website, a dealer website, a third-party website or simply walking into the showroom of a local dealer. Brands that can connect those channels and deliver a personal customer experience while doing so can be better positioned to win. Consider the finance and insurance aspect of buying a vehicle and services like extended warranties, gap insurance, or increasingly connected vehicle subscription services. They all come into play and there are just so many ways that people interact and expect those interactions to be personal. Having the ability to deeply understand consumer behavior, preferences, timing and then make it all personal, that is the challenge that the industry faces.  How do you create a consumer experience that brings all of that together, that is very personalized and that is done at scale and done in ways that are ethical and done with privacy built in? That is what we do at Acxiom.  What are you thinking about, what is next? I am really interested in how various segments of the U.S. market will adopt electrification. It is not a one-size fits all model. Acxiom has a point of view publishing in June where we will be presenting a bell curve that is essentially a view of EV adoption among people in the U.S. Not all consumers are in the same position, which means marketers require different approaches in terms of marketing; the mission is different for people wherever they fall on the adoption bell curve. People on the far right side of the curve shouldn’t be ignored today regardless if they are likely years away from buying an EV. They simply require a different message than that of people ready to buy today.   I am also thinking about the customer experience at the charging station and whether a good or bad experience may be associated with the type of charging station or the vehicle brand itself. Right now, that’s an unanswered question, but my sense is if a new adopter of EV technology has a poor charging experience, the person might equate that experience to EV technology and the brand EV they are driving and not so much the charge point provider. When you consider your in-depth understanding of consumer behavior, what do we know? We know that when it comes to autonomous technology, consumers are interested in technology that protects them from themselves. Interestingly, the paradox is that the willingness to pay for autonomy is not high. I think that presents an interesting opportunity when we consider connected solutions like infotainment and vehicle health monitoring, which, in contrast, is a faster and more near-term opportunity.  Right now, when we consider the regulations and the fact that there are somewhere between 15-16 million new vehicles entering the market in the United States annually, each one with about a 12-year life cycle, it is going to be a long time before we get to fully autonomous vehicles everywhere. The more near-term opportunity to connect with people will be through in-vehicle technology. That experience inside the vehicle, greater convenience within the vehicle, managing your calendar, your groceries, your digital communication from inside the vehicle, all of that, can happen in the vehicle right now. What I also really love about this technology is that it can be built, it can be upgraded, it can be scaled much faster than autonomous technologies can. We are going to likely see a lot more forward motion regarding what happens inside the vehicle in terms of connecting with consumers and creating experiences. Of course, the development of autonomous vehicles will continue to move forward but there are clear opportunities that are technologically rich and where the ROI and the value to shareholders is clear and scalable. “When we think of people, these are not experiences that are foreign to them. When you get an update on your phone, you don’t consider that a recall; your phone is now better because it got updated. Same should go for your vehicle. If your car is pushed an update, your engine can run more efficiently, the software inside your vehicle has been patched to provide better cyber security. Your car is better: The vehicle that I bought last year is better today. That is a very fundamental shift in how consumers view their vehicle." There were so many ideas shared in our session, so many perspectives gained. Steve is a deep thinker and it is apparent in everything he does, including the way he speaks and tells stories. His ability to seamlessly shift from technical, data driven conversations to sharing his personal views on the industry is flawless. Steve will be moderating a panel at CXAUTO2022 which will include Jeremy Beaver, the CEO of the Del Grande Dealer Group ; Richelle Estrella, Department Head – Customer Data Lab at Honda North America ; and Myles Rose, Automotive Digital Strategy Director at Acxiom . This Panel will be discussing “Harnessing the Power of CDPs to Nurture A Customer First Philosophy That Drives Profitability and Loyalty.” CDPs offer automotive brands the opportunity to build modern marketing platforms where customer identity serves as a foundation on which automakers and dealers can build strong, first-party identity solutions while also regaining control of marketing decisions related to targeting, media spend and attribution.
Let The Government Be Your Customer Service Department!

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Three super-large dealership groups are trying it!   Here’s how it’s going for them so far… Carvana lost the ability to transact in Illinois according to  Automotive News  (May 16, 2022) because, “The Secretary of State's police department opened an investigation into consumer complaints about Carvana in February, (Henry) Haupt told  Automotive News . The investigation spans about 90 signed complaints, Haupt said. He said he couldn't provide an exact date as to when Carvana might see the suspension lifted.” According to a press release from the Texas Attorney General’s Office: “Texas Attorney General Ken Paxton filed a deceptive trade practices lawsuit against the online used vehicle dealer Vroom Automotive LLC and Vroom Inc., which also sells cars to Texas consumers under the name Texas Direct Auto. The lawsuit alleges that Vroom has misrepresented and failed to disclose significant delays in transferring clear title and obtaining vehicle registrations, burdening thousands of consumers. The State also alleges that Vroom has misrepresented and failed to disclose vehicle history and condition and terms of financing and approval—all violations of the Texas Deceptive Trade Practices Consumer Protection Act. According to the lawsuit, Vroom has not managed its growth effectively, leading to inadequate systems and procedures that have harmed Texas consumers.  Over the last three years, consumers have filed over 5,000 complaints with both the Better Business Bureau and the Office of the Attorney General against Vroom and Texas Direct Auto.”  According to the Federal Trade Commission’s (FTC) Press Release dated April 1, 2022: “The Federal Trade Commission and the State of Illinois are taking  action against Napleton , a large, multistate auto dealer group based in Illinois, for sneaking illegal junk fees for unwanted “add-ons” onto customers’ bills and for discriminating against Black consumers by charging them more for financing.  Napleton will pay $10 million  to settle the lawsuit brought by the FTC and the State of Illinois, a record-setting monetary judgment for an FTC auto lending case… A survey cited in the complaint showed that 83 percent of buyers from the dealerships were charged junk fees for add-ons without authorization or as a result of deception. One consumer cited in the complaint reported that the dealership located in Arlington Heights, Ill., charged him for nearly $4,000 in add-on fees after he’d paid a similar amount in down payment.” So, from the outside looking in, it appears these three (3) organizations do not have procedures in place to handle their customer queries, issues, and problems. So, by default, by attrition, or by apathy, they are ceding control and allowing the regulators to fine them and suspend them, thereby driving the dealerships to manage their own business affairs. (Good pun, right?)                                                                                                                 In the Napleton matter, a staggering 83 percent of buyers said Napleton took advantage of them. Let’s examine that statistic even further. In order to gather the information about the 83 percent, Napleton had to allow the FTC to have access to its customer files.  The FTC must have had quite a lot of leverage for Napleton to agree to give them that access.  Further, 83 percent cannot be simply “miscommunications” or “misunderstandings.”  It’s an astonishing number which cannot be explained away. Let’s keep this simple: Handle your customers or the government will.  
Communication Has Changed: A Conversation with Joe Shaker

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How do you interview someone who is truly an industry heavyweight, a Massachusetts Dealer of the Year, the CEO of a Tech Company, and who has been interviewed so many times before? You prepare. And then you scrap your prep notes and questions and you allow magic to happen.  “I think the first-mover advantage is the first person to learn, right? Whoever learns first, has the advantage, and we've learned a lot.” Meet Joe Shaker , owner of the Shaker Auto Group and the CEO of TruVideo . Someone who is “trying not to be famous,” doesn’t exist on LinkedIn and openly shares his story with honest excitement, energy and a formidable presence that, honestly, left us invigorated.  Below is his story, in preparation for CXAUTO2022 . When I tell the story, I tell it from a point of: these are the real problems, this is what we've learned and this is what we did when we learned it. And then guess what? We learned something else. So when I say it's genuine, it's actually true. I wanted customers to see what they're paying for. What is being disrupted, what is changing? Communication is changing.  I think one of the key things that I like to remind people, and what I've learned myself, is that we forget about the big picture. Sometimes when we're talking about service or sales we get focussed on details that don’t matter. I tell Dealers: don’t change the way you do business, change the way you communicate.   Overall, 95% of customer experience is largely embedded in how well or how poorly you communicate. So we need to really focus on how we communicate and what it is that we are communicating. I like to joke around with the OEMs. I love it when I go to the meetings and people talk about trust and transparency or when the marketing team talks about meeting people on “their terms”: Yeah, just a quick question. How do you deliver on that? How would I execute that? Oh, you don't know. You're just saying that. Okay, great. Thanks for the punchline. So what we end up doing is going back to the theory without an execution model, but we can solve these problems! The stars have aligned for TruVideo and the reason I say that is because texting is the most used function on a phone and 10 billion videos are being watched daily on Facebook alone. Customer behavior has fallen inline for us, and with phones now taking high quality video, there has been an alignment between consumer behavior and technology. Asynchronous communication is how customers want to communicate. They love it, they click on it, they open it and, if you want to do business with a customer, it's the best way to maintain a relationship based on all the data and stats. Also, because of where we are in this journey, we can now also see how customers are interacting with the communication.  If we take it a step further, focussing on the customer experience, CX personalisation is probably the strongest underpinning right now. Video has provided this personalization which has allowed these communications to explode on the customer experience front as well as dealer revenue. Simultaneously, you get to take two bites out of the same apple. “TruVideo really took off within the sales department of forward thinking Dealers” We have a case study that analyzed 16 stores, within a large group, during December of 2020. The case study showed that when you sent the video to a customer that personalized their experience, the appointment set rate and show rate, both increased. We all know that when we are talking about leads and customers, we are looking at how many leads were generated, how many appointments were made, how many were confirmed and how many customers showed up to those appointments. The next layer, percentage wise, is how many vehicles were sold after this whole process. Any change on any level, with any of those factors, makes the number at the bottom go nuts because it’s a multiplier.  Well, with the case study group, they sent out just under 7000 videos and sold around 560 more cars during COVID than they did prior to the pandemic in December 2019. We started to realize that so many people were watching the videos over and over again and sharing them, we realized this data is actually more valuable than the website data. We can send videos, we can scrape words and phrases, we can really grab all this rich analytics and data and reach customers.  How are you able to manage your duties within Shaker Auto Group as well as deliver on your goals as CEO of TruVideo? One of my favorite quotes is: “Commit to the process, and surrender to the result.” Our Business, the car business, has been largely built around processes. When we hire, we share our process, our system, which we are willing to hire into. It is not a blank slate. We are willing to hire you to work within this ecosystem and we have spent a lot of time creating a systems and process driven environment. This means that hiring correctly and training people to thrive within our environment, really is our big picture.  We do behavioral profiling so that we get the right fit within the environment and we also have a different way of paying our people versus other Dealers. The reality is that someone like me is usually buying more stores to grow further. I have chosen to diversify what I do and how I do things through software and technology. I have a great management team that we have cultivated in order to run the process environment and this allows me to grow in different ways typical to the industry.  In an environment where everybody is focussed on training, how do you truly integrate training into your environment? Theory without execution is hallucination, and I don’t like to hallucinate. People do and say things, buzzwords, but don’t execute on them. When people say they do training, I want to know what that means. Usually, theoretically they are right but I want to understand how they execute on these things. And I think that's really the secret; we won't sign up with vendors if we don't believe we, as the dealership, can execute on it. There is a difference between those who flippantly use  training  as a component of their operations and ourselves. It’s part of our system, our process, it’s a religion with us. What can we expect at CXAUTO2022 TruVideo has really been an incredible experience for us and some of what I'll be talking about at the Event is  conversational commerce ; what it is and how we found ourselves there. We knew we were doing something different but found out that the concept existed, we were just executing it in a very unique way. When we started learning about the communication chain, we realized everyone was getting the same message. We had to fix that and, then, that’s when we really started learning. We spent the first few years really focussed on solving the customer problem. The word  engagement  slips in all the time but when we really think about it, has the message been delivered and not just the text lines? Maybe we know the open rate of an email, but do we really know anything else? “I want to talk to the Doctor, not to the Receptionist” In 2021 we released the ROVI Report; We wanted to share data from our first 7 million videos. One OEM partner that shared data with us showed us  a 1.1 million repair order sample. The ROs that had video were $55 more, and, simultaneously increased CX scores. Customer “Intent to Return”, went up 4 points on the Net Promoter Score and “Value for Service” went up 3 points on NPS. Some of our OEM partners have exploded on the JD Power Service Index; so we are truly seeing the impact on the customer.  Following the data has shown us that we can not only eradicate doubt, but fix the communication chain. We realised we had data when we saw 35% of videos being shared in service. The inspection from the technician was no longer diluted by going through various people. The same transparent message was now going to the advisor, customer and any friend or confidant.  What matters about data and analytics is: how do we make it actionable? How many times are people watching, sharing, what is the real time data? We can show that through our dashboard, allowing managers to know what they need and allowing the Dealer to control the communication.  Our high-energy conversation ended with us sharing our personal views on how the world needs  more . More communication, more technicians, more perspective, more creativity and more acceptance of differing skills. Especially when it comes to breaking negative cycles through inclusive thinking.  See Joe live at the CXAUTO2022 in Marina Del-Rey next month! We would highly recommend it!
Curing your COVID Hangover

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If you ordered a new vehicle and were told it could take a few weeks to come in, and all you had to do was leave a deposit and wait, you’d be pretty excited right? Well, what happens when a post pandemic global chip shortage starts to squeeze automakers’ abilities to deliver their vehicles to their dealer network? Dealers are now delayed in scheduling retail deliveries with their customers, and have to disclose missing items. The chip shortage is creating catastrophic wait times, crippling dealers’ ability to offer vehicles containing the high-tech features many customers want. The outward-sensors are controlled by microchip processors and therefore some manufacturers are building vehicles without the features altogether. Others are simply pausing production. Either way, it’s not a happy problem to have. There are a variety of anomalies occurring in the automotive industry currently. The biggest challenges we face include: managing customer expectations, factory constraints, and used vehicle valuations skewed by current market conditions. The values, because of low supply, are at an all-time high. Meanwhile, increasing delays leave some customers wanting to back out of their orders. The others customers remain waiting weeks and months more. When they do finally take delivery, the sales process suffers greatly. In the customer’s mind, they were lied to and ignored. They are extremely frustrated. They are anxious about getting their new vehicle. Increases in MSRP and egregious dealer addendums, have customers feeling squeezed by the charlatans. After being ignored by their salesperson for the last few months, they have no patience left for our process and they certainly aren’t interested in spending extra time in the business office listening to our pitch. The customer has the cashier’s check in hand, made out to the penny, and can’t wait to torch you on the factory survey. Those customers are also highly likely to leave a really nice 1-Star Google or DealerRater review. Did I miss anything? Vehicle sales plummeted to some of the lowest levels at the start of COVID and now that we have sold through the bloated inventory, we struggle to build back up again. We are reminded that after enduring what we have all experienced during this pandemic, including its shortage repercussions, people’s psyches have changed. Not only our employees, but our customers too! It’s time to re-adjust our approach, our attitudes, and our actions.  To fix this, we start with an attitude adjustment and increasing the amount of engagement. Simply reach out periodically with updates, and let your customers know what’s happening. It makes people feel nice when you call or text them. It makes them feel like a priority. They are happy you didn’t forget them and they know someone is paying attention to their vehicle and its arrival date. We change our negative attitudes regarding low inventory, it’s low everywhere. Next, pay attention to our appearances and the vibe we give off. When people are dropping $100,000 on a new Escalade, they want to know we care about their purchase. Finally, take action! Start realizing one of the biggest perks our industry is experiencing - low volume and high profits.  How fortunate are we? You’ve never had to sell fewer vehicles for more gross profit in history. Commissions are at an all-time high and life is pretty good considering. Get excited about having more time to spend with each customer. During busy times when we give cars away for little to no profit, we are always rushed. We never seem to get quality time, connecting with them and solidifying meaningful relationships. If you spend extra time with customers now, you can set clearer expectations. This allows you to manage communication more effectively during the waiting process. This ensures the delivery is more successful and brings the customer back again for their future purchases in sales and service. It’s time to get re-connected with our customers and stay there.  
How Combining Agile Thinking and Acknowledging the Individualism of the Customer is Disrupting Auto Finance

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In the post-pandemic world, the, in some ways forced, adoption of digital has had resounding effects on the purchasing process. The pandemic created an increased sense of digital comfort amongst consumers. As consumers began to rely on digital platforms for everything from shopping for groceries, to meeting with friends, to job interviews, one of the more profound developments has been the upward surge in consumer driven research capabilities.  With access to information through digital applications more prevalent than before, the new, digitally comfortable customer, can educate themselves prior to making any form of direct engagement. This greatly impacts the playing field and changes some of the traditional metrics previously held as decisive factors when it comes to digital marketing. In preparation for his upcoming presentation at CXAUTO2022 , we met with Lewis Scott, the Director of Marketing: Digital and Field Performance, at Byrider. Along with sharing his story, Lewis gave his expert opinion on the current state of the industry, as well as what him and the team at Byrider are doing to solidify their presence (and the future of automotive) through vertical integration, redefining the customer and the full customer journey.  Growing up in Southeast Michigan, Lewis was destined to build a career in automotive. Having interned at Chrysler’s parts division, MOPAR, Lewis moved on to join Chrysler Financial once he had graduated from St Joseph’s College with a bachelor’s degree in Business Administration and Management. In 2012, Lewis and his family relocated to Indiana and, with the Byrider Headquarters situated in Carmel, it seemed like the perfect place to settle down and establish a root structure. Byrider’s in-house proprietary approval platform and in-house financing, has supported the establishment of 32 company stores and 114 franchise rooftops. Lewis has spent the last decade with the Company, moving up the ranks from an underwriter to where he is now, directing marketing for digital and field operations.  Prior to being promoted to Director, Lewis worked on the Franchising side as a Franchise Consultant, which, along with the exposure gained throughout his tenure in the industry, uniquely positioned him to understand the complex nature of consumer behavior within the automotive industry.  The Metamorphosis of the Customer The customer is educated: they want their answer online, virtually, remotely, digitally. Before they decide if they want to give you their business and buy a car from you, they want to understand if they can get approved. In the old days, circa pre-2016, customers would call your store, look at newspapers, look at automotive ads, come up on the lot, “kicking tires” so to speak, and right now, customers are comfortable with and require an experience that is digital and remote.  Our ability to build relationships and engage in experiences online has become the expectation. Customers want an experience, they want to know what you have, what you stand for; they want to know about the business. Customers now want to understand the journey upfront, what is the approval process like and before deciding on whether or not to commit, they want to understand both the pre- and post-sale experience.  Digitalists versus Traditionalists When we consider the sales methodology, I am a product of both.  My background is firmly established in the traditionalist model of sales however, it is my role to ensure that my team understands the importance of incorporating a digitalist perspective. At Byrider, this means equipping ourselves to recognize the potential embedded in a consumer through digital engagement.  A hybrid model means that, whilst we acknowledge that the traditionalist process still takes place, just later on down the line, digital is here, now. That is what we are seeing, a mixture of both approaches but a transition or shift in terms of the sequence of the engagement and process.  Although it will likely be two to five years before we see the full spectrum of digital adoption across the board, the facts remain, 85% of our engagement comes from digital, mobile specifically.  My role is really about the sales funnel, above the attributed lead or captured lead. Leads are no longer what is in our CRM, those consumers landing on the website, looking for information - by definition, that is a lead. How do we get that customer more engaged in a sales funnel? The answer comes down to overall brand engagement. We are able to engage customers through sharing knowledge of who we are and what we do.  Byrider has 32 company stores and 46 individual franchises that account for over 114 rooftops. We come from many cloths including traditional dealerships, some have been key employees from traditional or captive finance, some come from entrepreneurial backgrounds and there is success in this combination. However digital is forcing traditional to realize you can no longer come at this from a purely traditional route. Consumers want to know if they are pre-approved, can they get approved, whether they qualify for the vehicle, all before they come see you. That is a digital mindset and a digital scope. From the perspective of managing the anxiety that comes with a hybrid approach, training and development can ease the transition. Historically, we were able to deal with objections while a customer physically sat in our cubicle, we now find that we need to handle these objections from afar through telecommunication and digital channels. On the upside, those customers who are calling, are doing so because they have seen our vehicle online. Those submitting information to you, are showing deeper engagement from a consumer intent to purchase. In terms of managing the gap, Byrider has embraced web chat and by doing so, we work towards meeting the digital needs of our customers.  What we are focused on, is determining which communications with customers can be automated, what can we do to support the activities of our customers in order to make them comfortable to self-serve.  The ability to buy and get approval, the ability to finance, incorporating the reality of bad credit, new credit, no credit and facilitating real life scenarios such as job gaps, multiple jobs, non-traditional employment; these are all the things we can take into consideration. Through our in-house financing, we are the dealer, the underwriters, the service shop. All entities of our vertical integration are managed with the customer ownership experience in mind, and this is what makes Byrider different.  Our operations are uniquely set up to truly be there every step of the way and keep our customers on the road. Through these three pillars of vertical integration, sales, underwriting and service, we can support the customer at the most critical steps of their journey.  From start to end, Credit For Being You is an agile approach to an inclusive offering. The beauty of vertical integration is the agility that we can employ, we are able to consider the ability and willingness to pay which is not possible through a traditional model. We are able to consider our customers through a lens which is not afforded to them when it comes to an automated credit platform.  As Lewis and I neared the end of our conversation, we reflected on the sense of honor that came with working in a Company whose principle business operations meant that he could proactively play a role in people lives, knowing that the Team at Byrider are the reason that some families can get to work in the mornings. Themes of accessibility and the ability to approach the customer from an individualistic perspective, whilst driving business forward, is what happens when you apply agile thinking to a community driven industry.  We also got some crib notes on the “top secret ideas” that Lewis will be sharing at CXAUTO2022 . We highly recommend seeing him in person.  See more about Lewis here
Six (6) Perspectives On The New GLB Safeguard Regulations

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The new Gramm Leach Bliley Act (GLBA) regulations aren’t going away and become effective on December 9, 2022. You don’t have to agree, but you do have to comply. If you haven’t started already, it’s time to begin the work of parsing out how you will respond. I’ve asked various industry experts to chime in on how you should focus your efforts. Here’s what they had to say: Atul Patel CEO, Orbee  “Occasionally you get a nudge to rethink what you’re doing. While it might feel like it’s more an elbow to the ribs, the FTC Safeguard Rule that is part of the Gramm-Leach-Bliley bill is forcing auto dealerships to take their customer’s data security seriously. We find this to be the biggest opportunity for dealerships to   take back control over your data that is created on  your  properties, from  your  media investments, by  your  customers. When your shoppers give you their Personal Indentifiable Information (PII), they believe it was to you. But what is more likely is that it was to a third-party such as a trade-in tool, credit form, chat, and so on. We restructure the way data is created, stored, and activated. This offers the clearest path to Safeguard Rule compliance while benefiting your customer experience.” Jim Lawrence  COO, Sensitive Data Protect, LLC “There are 5 steps dealers should take to establish a good-faith compliance effort to address general cybersecurity, the FTC's Safeguard Rules, the ongoing battle against "phishing," and ransomware attack prevention:  Perform cybersecurity testing to find gaps in consumer facing IT infrastructure and behind your firewall.  Establish the policies and procedures and trainings to address the gaps and evaluate the investment options for ongoing IT security preventative measures. Make sure to review the difference between a "bundled" approach to cybersecurity versus a piecemeal, single-point solution.    Partner with an experienced automotive service provider who knows where the sensitive consumer data hides on your DMS and the third party software applications that share your client and prospect database.   NOTE : Dealers' are now responsible for their customer data. Their liability doesn't stop at the edge of their lot, it now stretches out to your third party dealer service providers. Approach your cybersecurity insurance provider about all this "Good-faith Compliance Effort" because they value and reward dealers with lower premiums and deductibles who attend to the needs of their cybersecurity in a "bundled" more comprehensive way.    SPECIAL STEP : If you're in the buy/sell due diligence process or even considering it, show your dealership's ability to protect its operational and sales value other dealers can't with the documentation of your good faith cybersecurity effort.” Michael Tuno President, ARMD Resource Group, LLC “In October of 2021, the FTC updated the 2003 Safeguards Rule to reflect the sign of the times.  While the industry is buzzing about this update as if it is something new, it simply is a rule that is reflecting the current state of the industry and the ever-growing risk to dealers with protecting customer’s information, both paper and  digital. The term “qualified” has been added to describe the seemingly elusive role in a dealership of a “CCO”.  The need to document all the digital audits and deploy the risk mitigation steps like multifactor authentication etc. have been added.  An incident response plan to document the dealer’s plan to deal with a breach has been added.  Vendor risk management continues to be a critical task, even since the 2003 days. The FTC is going to hold third parties responsible for any customer information in a more stringent light.  At the end of the day, on December 9, 2022, dealers are advised to document all these updates to the Safeguards Rule.  If it isn’t documented, it didn’t happen!    At $43,792 per day per violation, not to mention UDAAP or UDAP, (especially if you are using the FTC boilerplate privacy policy at your store), it can get very expensive very quickly if this law’s requirements aren’t met.  Déjà vu!” Hao Nguyen General Counsel, ComplyAuto “What we've seen is that the revised federal Gramm-Leach-Bliley Act's Safeguards Rule ("Revised Rule") continues to confuse dealerships across the country on how to exactly fulfill these new obligations. Many folks are talking about it -- their attorneys, state and national trade associations, and other dealers -- but none of them provide a cost-effective solution to meet the dealers' needs.  We work closely with a dealership's IT company or third-party managed service provider ("MSP") as two halves to a pair of scissors to get the dealership fully compliant with the Revised Rule. We help create required documentation (the Information Security Program and all of the required plans that go with it), provide employee security awareness training, execute phishing simulations on employee emails, perform penetration testing and vulnerability scanning as well as risk assessments at the dealership, and help manage vendor requirements in signing Data Processing Agreements and completing vendor risk assessments. Not only will this help fulfill the Revised Rule but also potentially affect cybersecurity premiums. If your clients have not experienced it yet, dealerships across the country tell us that their quoted premiums have increased two to three hundred percent for this year. Implementing our services to bolster your data protection and cybersecurity protocols will go a long way in showing them that you place a priority on data security and will possibly reduce your cybersecurity premiums (or get coverage in the first place).” John Acosta  CEO, Vtech Dealer IT “Compliance is like a marathon. Come the end of the year; you want to be on mile 22 rather than mile 3 of the race. Some of the GLBA compliance requirements are major systems upgrades that take time to set up properly. Start planning now.”    Of course, he’s right.  Here are other GLBA considerations: Is all of your customer data encrypted? Do you have endpoint protection throughout the dealership? Do you have a data retention policy in place? Have you implemented multi-factor authentication (MFA)? Do you have a written “incident response plan?” Have you completed cyber training for all employees?  …and there’s more… To practice optimal risk mitigation, here, begin by figuring out where your biggest areas of vulnerability are and build out your program from there.  Feel free to reach out to any of these folks (including me) if we can answer any questions.  We are happy to receive your call.  Cheers!