ADDENDUM TO GUIDELINES
The attached addendum is for internal use by NAAA member auctions in determining how to make the recommended disclosure. It is considered a legally protected document, and as such should not be shared.
ADDENDUM TO GUIDELINES
This addendum is for internal use by NAAA member auctions in determining how to make the recommended disclosure. It is considered a legally protected document, and as such should not be shared. For the purposes of these hypothetical cases DOE will be the consignor of Third Party Vehicles at the Auction. All disclosures should be as prominent and in the same location as the itemization of charges and other transaction disclosures.
- Case I - DOE requests or auction offers to raise its sale fee by $XX or charge a new fee on each transaction and to periodically remit all or part of the increased fees to DOE.
Recommendation: The Auctions normal fees should not be inflated to bury a payment to be made to DOE. The new or additional fee, which is to be remitted to DOE, should be identified as accurately as possible. Some suggestions are DOE Administration Fee - $XX, DOE Rebate - $XX or Rebate to DOE - $XX.
- Case 2 - DOE requests or Auction offers to pay to DOE a rebate of $XX per car sold.
Recommendation: The rebate should be disclosed in a memo as follows: DOE Rebate - $XXII or Rebate to DOE - $XX
- Case 3 - DOE requests or Auction offers to periodically pay to DOE a rebate of from $O-XX per car sold based on the volume of cars sold.
Recommendation: The possible rebate should be disclosed by a memo statement as follows: DOE may be paid a rebate on this transaction at a later date.
- Case 4 - Auction remits to DOE all or part of a Buyers Fee on each transaction.
Recommendation: A memo statement should be made as follows: DOE may be paid a portion of the Buyers fee on this transaction.