What this checklist covers
The F&I Compliance Checklist is a 15-point scorecard for credit applications, disclosures, lender communication, add- on products, customer consent, adverse action notices, menu selling, and deal documentation. Each criterion is scored from 1 to 5 on what the auditor sees on the day, and every gap goes into an action plan with an owner and a close date.
AutoSmart tip: F&I compliance carries the highest regulatory penalty exposure of any dealership function — CFPB, FTC, DOJ, and state AG enforcement actions in automotive F&I have resulted in multimillion-dollar settlements. The three most common enforcement triggers are dealer reserve disparate impact, undisclosed add-on products, and ECOA adverse action notice failures. All three are preventable through consistent menu selling, documented consent, and timely adverse action notice processes.
The checks
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Credit application and disclosures
- Is a completed credit application retained for every financed transaction — with all required fields completed by the customer, not pre-filled by the F&I manager?
- Is the RISC (Retail Installment Sales Contract) or equivalent financing disclosure document reviewed with the customer line-by-line before signing — with the customer given adequate time to read and ask questions?
- Are all required federal and state disclosures (Truth in Lending Act TILA disclosures, state- specific credit disclosures) included in every financed deal jacket?
- Is the dealer markup over the buy rate (dealer reserve) within the dealership's written policy limits — with any exception requiring documented management approval?
Lender communication and add-on products
- Are add-on products (GAP, credit insurance, extended warranty, paint protection) presented using a disclosed menu — showing each product individually with its price, so the customer can see and choose each item separately?
- Are add-on products presented consistently to all customers — not selectively offered based on customer demographic characteristics in a manner that could create fair lending exposure?
- Are the prices of add-on products submitted to the lender on the deal exactly as disclosed to the customer — with no products added to the lender contract without the customer's documented consent?
- Is the lender's credit decision documented in the deal jacket — including the approved rate, approved amount, and any conditions — with no changes to the approved terms without the customer's knowledge and consent?
Customer consent and adverse action
- Is the customer's signed consent obtained for each add-on product sold — on the menu or on a separate product consent form — confirming the customer chose to include the product?
- Where a credit application is denied or the customer is offered less favourable terms than requested (adverse action), is an adverse action notice sent to the customer within the timeframe required by the Equal Credit Opportunity Act?
- Is the Credit Score Disclosure Notice (Risk- Based Pricing Notice) provided to customers who receive a higher rate than others based on credit score, as required by FCRA?
Menu selling and deal jacket
- Is the F&I product menu dated, signed by the customer, and retained in the deal jacket — with the menu showing both the payment with and without each product?
- Is the deal jacket complete — containing the credit application, RISC, product consent forms, menu, lender approval, adverse action notice if applicable, and all required disclosures — before the deal is funded?
- Are deal jackets reviewed by the F&I Manager or compliance officer for a random sample each month — confirming all required documents are present and correctly completed?
- Is F&I compliance training current for all F&I staff — covering TILA, ECOA, FCRA, GLB/Safeguards, and state-specific requirements — with training documented and refreshed annually?
How to run it
How the scoring works
Before the visit, fill in the dealer or centre, the auditor, the date and the audit cycle. Then score each of the 15 checks from 1 to 5 on what you see on the day, not on what the site aims for, and add them up out of 75.
- 1Not in place
- 2Attempted
- 3Defined
- 4Managed
- 5Fully sustained
- Green60–75 · 80–100%Compliant. Keep the standard.
- Amber38–59 · 50–79%Improvement needed: a structured action plan within 30 days.
- Red0–37 · Below 50%Priority intervention, escalated to regional management.
Then close every gap
Each gap goes into the action plan tracker and moves through four stages until the auditor closes it.
- 1PendingOwner and close date set
- 2In progressWork under way, evidence gathered
- 3CompletedEvidence submitted for review
- 4ApprovedVerified and closed by the auditor
