With supply chains still shaking off the effects of the pandemic and demand starting to soften, OEMs are looking for new ways to cut costs. Clients and others in the industry have reported an increase in frequency of incentive audits. These have also started to transition back to on-site audits vs. desk or mail-in audits. Further, OEMs have been able to “do more with less” as they utilize and rely more heavily on computer-assisted techniques and targeted auditing to expedite their reviews and obtain the most favorable outcome (for the OEM).
In order to better understand these incentive audits and what dealers can do to prevent or mitigate the negative impacts of an audit, we spoke with Sherralyn Peterson, an Automotive Incentive Specialist who helps dealers improve their incentive management processes, train their staff, and prepare for incentive audits. Her input helped us to address some of the following questions around incentives.
What are manufacturers focused on?
Every OEM has incentive programs – none of them are the same and all of them are complex, and OEMs have a lot of tools that enable them to quickly validate a claim. One of the changes resulting from the chip crisis is that OEMs now watch everything and every vehicle very closely, and they know exactly where vehicles are at all times, from shipment to final delivery to the customer. It’s important to make sure you know the rules and requirements for delivery reporting and that you’re doing so accurately. For example, can you sell a vehicle before it hits your lot? Is it a retail sale or fleet or commercial sale? It’s also very easy for OEMs to use VIN look-ups to determine what incentives are available or if a customer was the original purchaser of a vehicle being used toward loyalty or similar programs.
What are some best practices for incentives compliance?
Incentive programs are complex and ever changing. With seemingly minor infractions enough to disallow a claimed incentive, sales managers need to know their programs inside and out. There needs to be an understanding that you can’t just plug someone into a role where they’re responsible for managing and reviewing incentives. They need experience and/or training. Even switching between OEMs can be difficult, and having someone master a particular program doesn’t mean they will be able to perform at the same level for another franchise. Specific and intentional training is imperative; prevention is a lot more effective than trying to resolve issues during an audit.
Dealers and their managers should also take compliance seriously and make their sales staff know that errors or incomplete information won’t be overlooked. Do what you can to get all of the necessary signatures and information before the customer leaves. It’s inefficient, ineffective and poor customer service following up with customers looking for additional information after they’ve driven off the lot, especially if it’s days, weeks or months later. Linking accountability to compensation is a great way to get results.
How do you get off/stay off the radar?
OEMs are more targeted in their approach to incentive audits. Dealers shouldn’t really be surprised if they end up selected for an audit as it’s most likely something they’ve done. Audits generally aren’t random, OEMs are obtaining information from various internal and external sources – DMV registrations, exporters, banks, etc. – and they are using this information to analyze and compare what you’re doing with other dealers and can quickly target anomalies. It’s important to make sure your team is well-versed in program requirements and follows through with proper documentation.
What do you do if you’re selected for audited?
In the event of an audit, you want to make sure you’re not surprised by what is in your deal jackets. Review any high-risk deals and get your paperwork in order, follow up on missing information, etc. Be aware of what not to show the auditors – you should only provide the minimum required information; unnecessary or irrelevant information should not be handed over. Along these same lines, control and be intentional about who is in contact with the auditor and how they are communicating.
Despite the complexity of incentive programs, they’re an important part of a dealer’s business and bottom-line, especially as interest rates reach 20-year highs and new vehicle prices continue to climb. Properly managing your incentive programs can help to make sure these are a tool available to your dealership rather than a compliance nightmare. Training, execution, and oversight are all important to any process, and that’s no different for incentives. Being proactive can help keep you out of OEM crosshairs and, in the event you are selected for audit, help to ensure you are prepared. For more information, consult an ARB Dealer Services team member for assistance in navigating the complexities of incentives.
by Matthew Marcoullier, CPA
Matthew Marcoullier is a senior manager at ARB. He focuses primarily on financial accounting and consulting services for auto dealerships, commercial businesses, and closely-held businesses. Matt previously served as a Senior Auditor for the State of Maine Department of Audit.
