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Addressing Concerns in New Auto Consumer Protection Rule · Leaders in Lending

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  You're listening to Leaders and Lending from Upstart, a podcast dedicated to helping consumer
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  lenders grow their programs and improve their product offerings. Each week, here decision
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  makers in the finance industry offer insights into the future of the lending industry,
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  best practices around digital transformation, and more. Let's get into the show.
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  Welcome to Leaders and Lending. I'm your host, Jeff Keltner. This week,
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  I'm joined by Paul Metry from the National Automobile Dealers Association. Paul,
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  thanks for taking the time and joiners here employer. I'm excited that we would
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  talking at a lot of stuff on the podcast, but auto is top of
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  my mind. But I wanted to start with the FTC ruling that you guys
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  are talking a lot about, So give me the background. I'm not an
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  expert in this space. I mean, like a little bit of regulatory,
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  a little bit of auto, but I my ven diagram of automobile regulatory is
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  somewhat limited. To help me understand what's going on here, sir Lane,
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  Well, the Federal Trade Commission, which is the primary regulator for dealers.
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  Last June, they proposed a trade r elation rule and they are concerned about
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  consumer protections. They believe a rule that would impose new duties and restrictions on
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  dealers would help to further protect consuwers. And we have been very critical of
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  it for a number of reasons, and maybe I can just take off a
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  few of those for you. And it really comes down to the process that
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  the FTEC followed in developing this posed rule, also the support for it.
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  Both of these we think were extraordinarily thin, and then of course it led
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  to what we think are very poorly thought out substantive provisions. So just to
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  quickly hit on those from a process standpoint, the FTEC was proposing a rule
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  or has proposed a rule that is nontracted by Congress, and they did not
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  proceed the notice of proposed rulemaking with any type of advanced issuance to inform themselves
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  on the subject. So there was no advanced notice of proposed rulemaking, no
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  request for comment, no outline or proposals for which they sought comment. There
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  is nothing on the front end to gather information to help inform the rule.
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  In addition, when they put it out, they also had very little coordination,
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  certainly with industry. We meet with FTC staff all the time, but
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  these individual provisions they proposed were never discussed, and we believe even with other
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  agencies that have authority of this area. One area that they touched on have
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  to be with credit disclosures and for dealer purposes. That's really in the domain
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  of the Federal Reserve Board, it's not in the domain of the FTC.
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  There was no apparent coordination there, and they're applying this on top of a
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  host of existing disclosures not just under the Truth of Lending Act, but also
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  at the state level. For example, California, they have a requirement that
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  before you'd entered into a transaction you would have to make all kinds of disclosures
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  related to voluntary protection products, which were a big focus of this rule.
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  It's not clear that there was really any meaningful coordination of the states on how
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  this will affect them, because even though preemption would apply with a direct conflict,
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  in most cases, there's not going to be a direct conflict. In
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  other words, a regulated entity comply with both the federal and the states the
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  end. And you really got to think through if you pile out a bunch
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  of disclosures and other obligations, how is that going to play out, So
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  we believe the coordination was very thin, which was a problem. In addition,
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  the comment period this was very rushed. It was only sixty days.
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  Now the FTC will do a sixty day comment period for much less consequential items.
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  I mean, it might be like the extension of a Paperwork Reduction Act
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  request, which is only a couple of pages in the Federal Register. This
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  is a proposed rull cut out a whole cloth. So they go ahead,
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  they put that in there, we have sixty days to respond. Naturally,
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  we saw an extension, as did many others, including SPA's Office of Advocacy,
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  and to us inexplicably that was denied. It's also surprising because the proposed
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  rule was accompanied with forty nine questions and answers, or they were seeking answers
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  to forty nine questions. Many of these you would do on the front end
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  to help inform the POSH rule. It was surprising to see that they're in
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  there. But they asked a lot of questions about the impact on business and
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  that type of thing, and we wanted more time to be able to do
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  an assessment. Unfortunately that was shut off. Also, as I'll point out
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  here, a moment. They propose a number of disclosures consumer disclosures, and
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  it appears there is no consumer testing of those disclosures. And for any federal
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  agency, that is a very basic step. You want to make sure that
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  if you're going to propose new disclosures to help inform consumers, that they actually
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  are going to serve their intended purpose, and you've got to look at what
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  the effect on the consumers. So it's very routine for these federal agencies to
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  go ahead and test the effect of any particular disclosure on consumers to see is
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  this going to enhance their understanding or detract from it. Unfortunately, that never
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  happened, So a lot of steps here were really short circuited. You know,
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  one thing I would say really highlights this. They did a purported cost
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  benefit analysis of what this rule would do in the market place. Obviously it's
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  going to cost business money to sure, but they say it's also going to
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  provide benefits to consumers. And the figure they used was thirty one billion dollars
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  over a ten year period. And you might ask where they come up with
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  that, and it is a too complex for us to cover in a short
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  podcast like this. Well, it really is not because it was done in
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  a very cursory fashion. They looked at three variables. They said, this
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  is going to save these disclosures and everything else we're doing. It's going to
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  save consumers three hours per transaction. They assume that. They say that in
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  the role and then those role making that's based on nothing. There's no support
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  for it. They just say it's going to save three hours. They then
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  come up with a value of someone's non work time, so they multiply those
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  two and then they multiply that by the number of transactions that motor vehicle dealers
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  do with consumers, and they used a greatly inflated figure for that. You
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  take us three variables, it comes out to thirty one billion dollars. So
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  it's that then it's that cursory really not well thought out, and unfortunately that's
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  really indicative of the whole exercise. So on the process side, a lot
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  of concerns and many that actually go well beyond that. Can I can I
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  ask a simple question here, how does the addition of disclosure. Not that
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  I want to bash the agency, because you can do that, but I
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  I want to stand at that business. But I'm curious how they're how does
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  adding disclosures to a transaction reduce the time of consumer spence? Like, what's
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  the logic behind that? Well, you would have to ask them the question
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  because I certainly know see if it's certainly not in this case when you consider
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  the disclosure. I'll hit on those in a little bit. But to your
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  Yeah, to your point, I think the only shaare estimation is that it
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  would inject quite a bit more time into it. When we talked about actually
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  what the disclosures are so or no more time and no more understanding, which
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  is like I remember when I bought my car. There's it's not a lot
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  of paperwork. And I hate to admit this on the podcast, I didn't
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  read at all in great depth and there were a number of disclosures that I
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  definitely like put my John Hancock on and said, this is just what you
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  do right, well, mssive thing. Sometimes as a sem more disclosures are
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  going to be more helpful to consumers, but that's why they consumer test and
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  they find out that that's not always the case. They lead there with a
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  better understanding of the process, and sometimes it requires more, sometimes it requires
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  fewer. With much testom yeah, and by the way, just one quick
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  footnote on that the FTC knows how to do this. The Bureau of Economics
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  in two thousand and four was looking at a HUD proposal in which they said
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  that a mortgage broker of the compensation they own, that is something that should
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  be disclosed not just in a HUD one, not just at closing, but
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  during the shopping process. So they did quantitative testing of over five hundred consumers
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  and they found out that even though it's very well intentioned, many of them
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  were selecting more expensive mortgage products because they were fixating out in this figure and
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  not the overall fosting mortgage. So they really said they should go back to
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  the drawing board of it. And that's why you do that type of thing.
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  It's just for this reason you try to figure out, yes, this
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  is well intentioned, but is it going to enhance hundred it does it really
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  help the under lying without a doubt. Now, in terms of the support
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  for the rule. That also, and we've been very critical of this,
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  and we could talk about that for some time, but I'll just give you
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  one quick example. They largely supported their rule with and reference to qualitative testing.
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  Consumer testing that was dotten, and let me just tell you how thin
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  this was. So in twenty seventeen, the FTC did qualitative testing of thirty
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  eight consumers and a single market washing DCU market nineteen that had bought new vehicles
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  nineteen that had brought us and based on that they came to some conclusions and
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  they came out with a report in twenty twenty which was a very large portion
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  of what they pointed to and supported this rule. Now, as many people
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  know, qualitative testing is not quantitative tests. Qualitative testing is usually used to
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  develop quantitative testing. You measure prevalence through quantitative testing, so to they skip
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  that quantitative step and they use this to help support the rule, and there
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  were problems with it. B on that the survey design plan for the qualitative
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  testing had a lot of flaws in it, and even more to the point,
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  the report that came out in twenty twenty on this qualitative testing, it
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  stated that it is not suitable for generalizable conclusions. And of course we know
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  that our rulemaking is an exercise in a generalizable conclusion, you're applying something to
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  an entire marketplace. It's not targeted at any one person. So real concerns
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  with the support for the rule. Now to your point about you know what's
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  in it and is this actually going to speed up or slow down the pins
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  or what effect is it going to have. Well, the rule does several
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  things, very broad. I'll get to the disclosure piece. But initially they
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  said that they are going to prohibit certain misrepresentations. Of course, misrepresentations are
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  already prohibited. In doing this to confer themselves confer upon themselves the ability to
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  find a dealer over fifty thousand dollars per violation, And the real concern here
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  is the clarity with which they defined the misrepresentations. Obviously there are certain things
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  out there that should never happen and should be penalized, but the way that
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  many of these things are worded, it's unclear what a regulated entity can or
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  cannot do. And when you now have fine authority of over fifty thousand dollars
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  per violation, remember these are dealers, not banks, so the capacity to
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  be able to a suit or absorb these violations would be much more difficult.
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  That is an issue. They also prohibited the sale of valueless quote unquote add
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  on products. Well, of course, no one should sell the valueless add
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  on product but it's very poorly defined, particularly in areas like gapway. They
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  have real concerns about the value that the GAP product would provide to a consumer.
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  Will, of course be extraordinary value. We've seen that mover and over,
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  but the way they defined is a big concern. So they've done that
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  type of thing. They have new advertising standards that would apply to dealers and
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  only dealers, not other regulated entities. But then to the point that you
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  have, which is disclosures, here's what they've required to happen in any type
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  of transaction. A few things they say, any time a consumer inquires into
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  a specific vehicle or from that matter, of monetary term or any financial obligation,
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  upon the dealer's first response, the dealer would have to provide the offered
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  price. Now the offering price is everything except for governmental feeds. Now you
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  have to do that whether the inquiry comes in writing words, comes in the
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  world. So that means if I'm a salesperson and you run into me at
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  the Bowling Alley and you make an inquiry into a specific vehicle, upon my
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  first response, I have to provide that information. It could be you're using
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  the chat feature on our website. It could be a text message you said
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  you could be in the showroom. It could come up from a variety of
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  different ways, and when you think about it, then the liability that attaches
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  to these violations. Trying to make sure that you're actually providing an offering price
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  on the first response when this can come up through so many different channels is
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  a real concern, and one has to wonder what's the value of you know,
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  if you think about it the first time, you and it's if I
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  had to give the offering price, I'm not going to know if you qualify
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  for certain rebates. I'm not going to know if other discounts are applicable,
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  So I'm probably going to default to something like the MSRP, which is higher
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  than when you're going to end up getting. So you'd have to ask what's
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  the purpose of the disclosure if you're going to have something more favorable. So
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  they've done that. Certainly, having to do those disclosures every time someone inquires
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  into a specific vehicle and a customer can ask about two, three, four
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  or five vehicles really ties up the process. But even more so, any
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  time that a dealer would sell a volunteer detection product, they would have to
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  get from you up to four additional written disclosures. So that is certainly a
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  time consuming exercise, and there's other concerns with it. I mean they use
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  terms in there like cash price that differ from the way it's to finding the
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  truth of lending act. So there's just some inherent confusion with it. We
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  just don't think this was well thought out. We think we would build a
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  lot of time into the process. They've also said with websites, a dealer
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  would have to go ahead and identify all of its voluntary protection products and the
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  price associate. Now that might sound benign, but consider how they define a
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  voluntary protection product. It's really anything that's not put on the vehicle or sold
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  directly by manufacture. So when you think about it, any part that comes
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  with a vehicle is something that is considered to be an add on product that
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  you would have to separately disclose with pricing. Now, dealers sell hundreds and
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  hundreds of potential parts and accessories with vehicles. This is a requirement that would
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  require when you consider all the different products they sell, probably over ten thousand
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  separate line item disclosures with pricing, and you have to ask yourself, is
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  that enhancing consumer understanding. And if what you're really trying to get to is
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  like the price of a prepaid maintenance plan or a gap waiver, is that
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  going to be something that's salient and available to a customer when you loaded up
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  all these other disclosures. And the other quick point on that is, if
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  you're a manufacturer like Kessler Arivian, even though you can be considered a motor
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  vehicle dealer under this particular proposed rule, you would not be subject to that
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  disclosure requirement because of the way they define it. Add Up, you know
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  you're the manufacturer, you'll quit in the product on the vehicles selling it directly.
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  So they say they want to level the playing field between regulated entities,
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  but here they've driven a wedge into it. And the last quick thing to
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  comment on is record keeping being would require dealers to keep the slew of records
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  from twenty five months, records of all those communications I reference, among many
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  other things. And that's unfortunate because they say that they're really trying to protect
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  the honest dealer. You know, I'll tell you the FTC over the last
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  ten years has taken thirty seven enforcement actions against enforcement against auto dealers. There
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  would be required here tens of thousands of dealers to keep a huge cash of
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  documents and the unlikely to bet that there's an enforcement action when none of their
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  current enforcement actions to our knowledge, have suffered from a lack of documentation.
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  So really, we think it's not selting that's helping the honest dealer. It's
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  hugely burning the on a stealer. And if there were a good cost benefit
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  analysis that would come out. So a lot of concerns with it. Again,
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  a poor process and very poor support, and we think it's supplant zomping
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  that it's not gonna be help. Yeah, I think your point of it
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  is pretty clear on the Yeah, yeah, you have and I have been
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  shy. I'm curious when I hear a story like that, and obviously I'm
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  sure there's a different perspective on it somewhere, But do you have an underlying
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  sense of what's driving the agency to move as quickly as they are towards something
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  that is not like, what's the driver for moving this thing through so quickly
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  without some of the more traditional analyzes, cost benefit analysis, more rigorous quantitative
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  studies, consumer testing, and disclosures. Is there a driver for why that's
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  not being done anything in this case. Well, well, they have a
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  very aggressive agenda. There's all kinds of things that they have expressed concerns with
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  and they launched rolemathe with for example, as you may have heard, non
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  compete clauses, they proposed a role to eliminate those, by the way,
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  not just with existing employment contracts, but future ones. And there's a notification
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  requirement. So they're they're very disposed to try to go after a lot of
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  phase through the rulemaking process, and here they feel that they need to address
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  concerners in the marketplace. You know, it's odd to us because none of
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  the things that are addressing lack of remedies today if there's some type of abuse,
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  so they really do not have to plug in the type of down.
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  So we think it's definitely overkill. We don't think it's wealth n out and
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  we think if they did go through that more deliberate process, they would find
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  and see any of the things they propose really or not. Let's shift a
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  little bit from rulemaking such an exciting I think, to enforced MAXs because there's
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  been a number of enforcement actions or lawsuits from Attorney's General in the auto auto
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  dealer auto finance space recently, what's your take on what's going on out there,
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  Like, I mean, you could go to specifics or just generally like
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  what's what what are the kind of trends that you're seeing, because it's been
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  like I feel like I open up the paper and every now and then I'm
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  reading more frequents out of headlines in the space than typical. Sure, yeah,
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  certainly. Well, the FTC has one area they're very concerned about is
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  exercise a pricing discretion, And certainly pricing discretion does have to be managed.
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  You want to make sure it's not done an arbitrary fashion or something that could
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  lead to discrimination. So that concerned is certainly a genuine concern, although the
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  measures they've taken to address it, we think are also poorly thought out.
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  But really you see anyse enforcement actions that there is concerned about price and discretion.
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  And one of the actions last year was always a year ago, it
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  was against a large dealer group. They had stated that they're looking not just
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  at pricing discretion as relates to a dealer participation, to the dealers the dealer's
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  portion of the finance. Yet also they're looking at other products that were sold,
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  you know, some of these voluntary protection products. Yeah, that's not
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  something we're aware of having happened. So they are applying it to that.
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  They did that again in a two in another action, or they look beyond
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  simply credit. It is beyond simply dealer participation. And also the Massachusetts Attorney
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  General under state law actually just took an action this year that involved voluntary protection
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  products based on the violation and state law. They had looked at whether or
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  not the pricing was done fairal and so there's a lot of focus on the
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  exercise of price and discretion. Yep. Certainly a lot of focus on voluntary
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  protection products as it relates to things like disclosures and consuer consent, those type
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  of issues. They've been very focused on that. Another thing the FDC also
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  has done is they have improsed individual liability and a number of these cases really
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  so it's not just against the corporate entity. In that case, from about
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  a year ago, they took action against the general manager of two of the
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  stores of the Stealership group. That was an addition to the corporate entity.
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  And then in October they actually took the action against the owner of the dealership
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  group as well as the vice president. So that's a trend that I think
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  will continue to see. Are you seeing I know that there's this interesting the
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  ecotomy between the regulations that apply to the dealer in terms of the finances financing
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  of the vehicle, and then the regulations that apply to the entity. Often
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  a bank that ends up purchasing and owning that contract with the longer term,
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  right, it's usually the risk that's originated the dealer then purchased by a bank
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  that has maybe a different set of fair lending standards. Testing that's being done,
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  and I'm curious if you're seeing as these things happened, any reaction from
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  the lender side in terms of their comfort working with dealers, how they're thinking
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  about managing the risks that they have on their side of the house. As
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  these kinds of questions are being raised, I think it's it changes the dynamic
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  a little bit. Is a great question to most of the federal laws that
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  are out there are applicable to both end. So the dealer is the initial
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  creditor and then the bank ask the creditors. So Truth in Lending an Act
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  and Federal Consumer Releasing dutt Ram Leach Bliley. We could go right down a
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  lot. These are things that apply to both, although the liability standards can
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  different. And also there is this FTC holder rule, so that somebody holds
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  a contract would be subject to the same claims and defenses that we're initially if
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  they pull against a dealer. So they do sometimes look at that from different
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  ways. But in terms of ways to mitigate views concerns, you know,
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  we have come out with a program. It's an optional program because it gets
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  into pricing, but it's based on DJ can set orders on this whole issue
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  of pricing discretion, one that pertains to deal with participation, a protus of
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  volunteary of auditorcract fox, and those are ones that we believe can be very
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  helpful and actually they've been referenced many times. So for example that actually the
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  FTC took against the Dealership group a year ago, they actually said them on
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  a go forward basis, if the dealership is going to dealer anticipation that they
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  would need to adopt a program that's similar to the optional program that we developed
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  that's modeled on that DOJ approach. And then even in October, the dealership
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  had actually adopted that program, but they said they did not properly implement it,
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  so they did not make that an option of vailable tale. So there's
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  definitely been a focus on those types of mechanisms. And then the Massachusetts ag
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  action with regard to our Voluntary Protection Products program stated that on a go forward
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  basis, the dealership would go ahead and to adopt that program by name to
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  help mitigate concerns about the exercise of pricing discression. And we have found that
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  many banks find a lot of appeal on They think, yeah, I know,
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  if you if you have something that's allowing consumers to benefit from appropriate discount
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  it's not based on a prohibited basis, but otherwise is kind of standardizing the
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  process, making sure there's more consistency. It's a good way to keep competition
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  in the marketplace alive, make sure it's based on appropriate factors, and otherwise
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  kind of smooth out what otherwise could be differences in price. Got it interesting?
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  Any of the other recent enforcement actions come to mind when you think,
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  you mean, there's also the case in New York wisident here is one against
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  a credit acceptance corps. Yeah, correct, Now, that's not against dealers.
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  They certainly referencedealers, but dealers are the dealer against I think that one's
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  an internest with the pricing discussion and who's getting out ultimately liability for her right.
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  They do take a look at that. Now. Of course, that's
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  a little different from some of the other things we've talked about because that actually
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  is not a consent order. That's a lawsuit. Yeah, front of acceptance
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  is responding to that. That will be sett them in court, So we'll
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  see where that goes. Those other ones are all consent orders, so well
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  they did. Yeah, I'd prefer consentator, I think, to being sued
• 22:10
  by a sturning gen on. I'm sure we're none of the sound like fun
• 22:12
  experience is to be honest, Um, there are state level regulatory Actually we
• 22:18
  talk about about the FTC, But what's happening the state level from a regulatory
• 22:22
  actions rule making point of view other than the enforcement actions? Are there other
• 22:25
  other trends? Are things you're saying going on that are impacting the space?
• 22:27
  Well, certainly a number of states very active. We've we've certainly seen that
• 22:32
  with things like gap waver, California's hats in legislation. But I think it
• 22:36
  doesn't underscore a point. And this is something by the way on that FTC
• 22:38
  where we follow very extensive comments, so anyone that wants more detail on that
• 22:41
  can look at that. But really, the States really do have a and
• 22:45
  it differs from location location, and they really have a very robust regime of
• 22:52
  harments that apply to bolitary protection roducts to the sales process channel into things like
• 22:56
  gaff wave and those really are place and we do see activity with that,
• 23:00
  so that trend is still there that tends to pick up generally speaking, and
• 23:06
  certainly there has been some enforcement theres SEA. I would love to get your
• 23:10
  take on. Most of the listeners podcasts are in the on the banking side
• 23:14
  of the house, on the dealers side of how I'm sure there's a few
• 23:15
  dealers who popped in now and then. But when you think about, you
• 23:18
  know, the totality of what we've been talking about and how that impacts how
• 23:22
  banks should be thinking about their relationships with dealers, their relationships to the audit
• 23:26
  finance side. What should they be thinking about keeping their eye on over the
• 23:30
  next couple of months, for the next year or two as they're thinking about
• 23:32
  how do I support my local dealers, but also manage my risk as a
• 23:36
  related party, but to but not directly and the dealers. Just a great
• 23:40
  question, and I think you know some of the areas that are really very
• 23:44
  important. I think we've touched on, certainly the exercise of price and discrection
• 23:47
  to really engage the dealer to make sure that that is something where the way
• 23:52
  it's being applied is structure and there is any approach to it that is going
• 23:56
  to protect the consumer, the dealer and the bank. Of course that's important.
• 24:00
  And then things like gapwaver refunds, there's been a lot of discussion on
• 24:03
  that. That's really something that you can have multiple entities involved in the process.
• 24:07
  You certainly have the bank that is servicing the agreement, so if you
• 24:11
  do have something like a default or repossession a pre payment, that's something where
• 24:17
  the bank first learns about it. But there's other circumstances where something can be
• 24:19
  canceled, and it really requires good communication between the dealer, the bank,
• 24:26
  and oftentimes the program administrator take their product and doing that to try to make
• 24:30
  sure that the consumers may hold that any refund rights are actually exercised and fulfilled,
• 24:37
  any obligations are met. Is very important. So those are two of
• 24:40
  the areas that we've think a tricklo sale. All right, and then I'll
• 24:44
  ask you one more question, which is I'm kind of curious to talk a
• 24:47
  lot about things that are going on that are you know, we don't like,
• 24:49
  or rules we think or learners. But I want to give a chance
• 24:52
  to switch to the positive sign Like what are the you know, is the
• 24:56
  association of auto dealers, Like what are the trends you're saying that are positive?
• 24:59
  That like changes the market that are they're positive the consumer, positive dealers,
• 25:02
  things that are like where's the future headed, not just on the regulatory
• 25:04
  side, but in general for the space, because it feels like actually a
• 25:07
  quite exciting time. It'd been a very weird time over the last couple of
• 25:11
  years, like lack of inventory and like, you know, a lot of
• 25:14
  dealers struggling with just you know, too many salespeople and not tough cars to
• 25:18
  sell, not because they didn't just couldn't could get them. And I feel
• 25:21
  like that, combined with digitization, it's a really fascinating time for the space
• 25:23
  in terms of how the car buying experience is going to ship. Give me
• 25:26
  a let's let's end on a more positive struct You're like, what are what
• 25:30
  are the positive trens you're seeing on the space? No other great question.
• 25:33
  I mean there they're certain there are many positive trends we are seeing. Just
• 25:36
  in terms of online impeachment with consumers. What are you're seeing as consumers get
• 25:41
  more and more comfortable with shopping and learning about products and they're online, the
• 25:45
  ability to provide all the information clear disclosures kind of give them all a good
• 25:49
  snapshot of what it's going back, it's stronger role time and that's a great
• 25:53
  process. More broadly, when you look at kind of a trend with evs
• 25:59
  and that type of thing, I mean, that's something that dealers have been
• 26:00
  very supportive of as considered demand for evs goes up, so certainly they are
• 26:07
  working with the factories to try to make sure that that demand doesn't mean as
• 26:11
  for inventory and the supply chain of disruptions and some of those challenges. Yes,
• 26:15
  that's you know, trying to make sure that you can meet considered demand,
• 26:18
  and there are expectations that regard. That is kind of an evolving situation,
• 26:23
  but there seems to be a little bit easy with that where in terms
• 26:29
  of you know, some of the supply chain shortages that had before haven't proved.
• 26:33
  It's not something that happens overnight, but I think we're certainly seeing that.
• 26:37
  And as for the transitions to EV as, a lot's going on.
• 26:38
  The factories are certainly trying to build more evs and the fleet. They're trying
• 26:44
  to get more of a charging infrastructure in place, and different factories are going
• 26:48
  about the different ways, but certainly dealers have been at the forefront of trying
• 26:51
  to make sure that happens. You know, one thing we've always stressed our
• 26:53
  dealers are indispensable to that process because at the moment, the EV purchasers tend
• 26:59
  to be in your more urban areas. It's ones where the income level might
• 27:03
  be much higher. But when you talk about a fleet that's vainly if not
• 27:07
  exclusively uvs, then you're talking about past market penetration and trying to make sure
• 27:11
  that consumers understand us there are concerns about range anxiety are addressed and actually you
• 27:18
  can sell them they understand the benefits tone Doing all those things can be a
• 27:22
  real challenge, and having in our case a network of over sixteen thousand franchise
• 27:26
  dealers in the local communities to kind of guide them through that process is supported,
• 27:32
  we think is indispensable, and so we're excited about that prospect and we
• 27:34
  think experience us excellent. Well, Paul, thanks for taking the time and
• 27:38
  join us today. It was a lot to cover. I learned a lot,
• 27:41
  I'm sure the audiences well. I appreciate you making the time and sharing
• 27:45
  your perspective. Thank you so much. Plugging with you help Start partners with
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