All in One Pricing??? A UDAAP Violation???

GUEST REBUTTAL

So, your agency goes through all the analytic procedures and comes up with an AIO price which includes Recovery Fee, Mileage, Flat Bed Fee, Keys, Storage, Redemption, Personal Property Inventory and Return.

You receive an assignment within 5 miles of your office and when you arrive the consumer comes out, hands you the keys and states he/she has cleaned all the personal property out of the vehicle. You drive/tow the vehicle to your storage facility where a transport company picks it up three days later.

There was no cost for a key, no cost to clean out and inventory the personal property, no cost for a flatbed, no mileage charge and no redemption fee yet you have included these costs in your “All In One” pricing and that is what you charge the lender who passes that fee on to the consumer increasing their deficiency balance.

You have charged the client for services you did not perform on this assignment and thereby created an abusive situation for the consumer.

It does not matter how many analytics you perform to reach your “All In One” Fee the bottom line is that consumer is being overcharged for the services provided on that particular assignment… and overcharging represents an “UNFAIR and ABUSIVE ACT” pursuant to UDAAP.

The CFPB has already stated that certain charges were unfair and abusive but your agency has included those charges and attempted to mask them in the “All in One” fee.

I feel this is certainly something the CFPB will be looking into… remember their name and the words “CONSUMER PROTECTION”.

Ron L. Brown

MCE, IFCCE, CCCO, MPRS, CARS, CFA