and/or non-warranty like circumstances, and disregarding the manufacturer’s 2024 stance that these categories should now be included. Surprisingly, the manufacturer reverted to the pre-2024 standards, approving both parts and labor submissions without any adjustments, and without reference to the prior year’s disagreements. When manufacturers apply policies regarding the qualification of repairs inconsistently and without rationale or notice in determining retail warranty rates, dealers are left with uncertainty and doubt regarding manufacturer expectations and intentions to reimburse their dealers at true retail. Conclusion Across all cases, one theme persists: inconsistent manufacturer application of evaluation criteria. Dealers have demonstrated that identical methodologies, repair categories and submission frameworks have been treated differently depending on timing, store or request type. This body of evidence illustrates how some manufacturers change their interpretation of statutory language, whether in designating “warranty-like” qualifications, adhering to state statute requirements or determining inclusion and exclusion of specific repair categories based on internal criteria. This is not an indictment of all manufacturers; in all fairness, there are several of them that properly adhere to statutory requirements and have a consistent application of their internal policies. For fairness and credibility to prevail in manufacturer-dealer relationships, evaluation criteria should be applied uniformly, transparently and consistently across all rate requests — regardless of year, dealer or submission type. Only through consistency can the process maintain legitimacy and support mutual trust between dealers and manufacturers. Joe Jankowski is the managing member of the Hunt Valley, Maryland-based Armatus Dealer Uplift, a firm specializing in retail warranty reimbursement submissions. Armatus has completed over 22,000 successful submissions nationwide. Joe has been personally involved in consulting on 25 retail warranty statutes and is widely recognized as a subject matter expert in this highly technical arena. Previously, Joe spent more than 20 years as CFO, COO and CEO of a large automotive group in Maryland. repairs reduced the dealer’s approved rate in 2023, while the inclusion of this category reduced the approved rate in 2025. Having taken notice of this contradiction, the dealer asserted a claim of disparate treatment, arguing that the manufacturer’s inconsistent rule application constituted an unfair practice. However, the manufacturer was unwilling to amend their stance, ultimately stating that their handling of the request in 2025 was aligned with the state statute’s guidelines, offering no further insight as to why the dealer’s requests were handled differently, year-over-year, following the same statutory guidelines. When manufacturers alter interpretive positions without a transparent rationale, they invite credible claims of disparate treatment. Even if statutory language supports flexibility, manufacturers should maintain internal consistency to preserve fairness and trust. Case Study 3: Year-over-Year and Store-to-Store Inconsistency Between 2020 and 2023, this dealer completed retail warranty submissions successfully under state law without issues, achieving full approvals for each request. Over the course of this time frame, the manufacturer in question consistently excluded certain repair categories as maintenance and/or “not warranty-like” — including brakes, wiper blades, keys, wheel locks and carbon cleaning, to name a few — from retail warranty calculations. In 2024, however, with no change to the language in the state statute, the manufacturer erroneously included these categories for the first time without explanation, significantly lowering the dealer’s requested rate. The dealer challenged the inconsistency, citing the handling of their requests in years past and the non-warranty-like nature of the now-included repairs. In 2025, just a few months later, the dealer proceeded with submitting new requests for both parts and labor, following the same policies that the manufacturer had followed from 2020-2023 — excluding categories consistent with maintenance 17
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