2026 Pub. 13 Issue 1

A Multi-Case Review By Joe Jankowski, Managing Member, Armatus Dealer Uplift Introduction Over the past several years, discrepancies have emerged in how manufacturers evaluate and approve dealers’ warranty parts and labor rate adjustment requests. Across multiple stores and years, dealers have observed inconsistent application of rules and policies, shifting and inconsistent interpretations of “warranty-like” qualifications, and contradictory inclusion and exclusion decisions. These inconsistencies — found in submissions for a given store year-over-year, in parts and labor submissions for the same store(s), and between similarly situated dealers — constitute what can only be described as disparate treatment. This article presents multiple documented examples illustrating how identical or near-identical repair orders and methodologies have been treated differently by the same manufacturer under changing or variable internal guidelines. Each case study highlights the lack of evaluation consistency, transparent standards and uniform enforcement of manufacturer policies across all dealer submissions. Case Study 1: Same Store Parts and Labor Submissions with Different Rules A dealer submitted requests for warranty parts and labor rate increases during mid-2025. The requests were submitted to their manufacturer in quick succession — both within a one-month period. After reviewing the labor request (which was submitted for review first), the manufacturer approved the dealer for a slightly reduced warranty labor rate, having made several adjustments inconsistent with rules and policies upheld in years prior. Just two days later, the dealer filed a parts request using nearly the same set of repair orders; 89 out of 90 days used in each request overlapped, with a variance of only a single day. Each submission was prepared under identical rules, with parts having been adjusted based on the manufacturer’s RO-by-RO feedback as provided in response to the dealer’s labor request. Despite the nearly identical range, the manufacturer cited and adjusted the handling of 19 entirely different repairs that were not cited in the manufacturer’s Disparate Treatment by Manufacturers in Warranty Parts & Labor Rate Increase Evaluations review of the previously approved labor sample. In other words, the manufacturer’s rules regarding what constitutes a “qualifying repair” had changed within just a 48-hour period. The dealer, therefore, requested that the parts markup be approved using the same methodology and logic that governed the labor approval, proposing an amended markup aligned with the original figure requested, rather than the three-point reduction resulting from this disparate treatment. When submissions are prepared utilizing the same methodology, manufacturers should ensure parity across evaluations. Divergence in review criteria between labor and parts requests undermines procedural fairness and erodes dealer confidence in manufacturer processes. Case Study 2: Statutory Interpretation and Shifting Rules In another case, a dealer challenged a manufacturer’s inconsistent interpretation of a state warranty statute, year-over-year, with no relevant change to the state statute in reference. In early 2025, the manufacturer in question cited the absence of “warranty-like” language in the applicable state statute, asserting that repairs completed due to damage/outside influence (rodent damage, accident damage and other factors that would never be covered under a manufacturer warranty) should be included in the calculation. This interpretation was completely off base, considering the entire intent of the statutory language is to include work that would be covered under a manufacturer’s warranty and to exclude work that is not. The manufacturer’s very own behavior contradicted their previously stated stance. In 2023, the manufacturer took the exact opposite stance to reduce the exact same dealer’s request, having stated that repairs completed due to “outside influence” should be removed from the calculation, only to reverse that position in 2025 when doing so worked to the manufacturer’s advantage. In both cases, the stance taken resulted in a submitted rate that was reduced; the exclusion of such 16

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