| Industry: | Automotive |
| Underlying Misconduct: | Consumer Fraud |
| Matter Type: | State Attorney General |
| Relevant Jurisdiction(s): | Superior Court of New Jersey, Chancery Division, Union County |
| Penalties: | Civil Penalties, Reimbursement of Investigative Costs and Attorney Fees, Restitution |
| Fine Amount: | 130,000 |
| Reporting Agencies: | New Jersey Division of Consumer Affairs |
| Resolution Form: | Consent Agreement |
| Agreement Date: | December 2, 2014 |
| Monitor Reference Term: | Compliance Monitor |
| Monitor Identity: | Unknown |
| Monitorship Term: | 1 Year |
| Monitor Selection Process: | Reporting Agency Advance Approval
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| Time to Propose Monitors: | Not Specified |
| Time to Engage Monitor: | 30 days from Consent Judgment date |
| Time to First Report: | Not Specified |
| Reporting Frequency: | Quarterly |
| Monitor Required Qualifications: | 1. Advanced approval by Reporting Agency
2. Shall not have any direct or indirect interest in, or relationship with, either the Division or Host Organization that would impede, or reasonably be perceived to impede, the Compliance Monitor's ability to perform the services under the Consent Judgment
3. Familiar with the Terms of the Consent Judgment
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| Summary of Monitor's Scope: | 1. Monitor the Host Organization's compliance with the Terms of the Consent Judgment as well as with all applicable State and/or Federal laws, rules and regulations as now constituted or as may hereafter be amended including, but not limited to, the CFA, the Motor Vehicle Advertising Regulations, the UCLL and the UCLL Regulations.
2. Monitor the Host Organization's compliance with its own internal policies and procedures.
3. Evaluate the adequacy of the Host Organization's internal policies and procedures to ensure compliance with all applicable State and/or Federal laws and to recommend any changes to those policies and procedures that the Compliance Monitor deems reasonably necessary to achieve such compliance.
4. Facilitate the resolution of Additional Consumer Complaints in accordance with Section 7.
5. Provide the Division quarterly reports.
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| Summary of Monitor's Activities: | Compliance Monitor's quarterly reports shall include: (a) Findings with respect to the Host Organizations compliance with all applicable State and/or Federal laws, own policies and procedures, and the Consent Judgment, including an identification of any compliance deficiencies; (b) Recommendations for curing such deficiencies and; (c) Summary of the disposition of Additional Consumer Complaints.
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| Monitor's Restrictions: | 1. Compliance Monitor shall not be employed by or affiliated with the Host Organization or any other entity owned or controlled by the Host Organization for a period of at least one (1) year from the termination of the monitoring period
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