Process & Policy: Gray Market Denial

Updated 3/30/21

Article Summary: This article outlines the definition of gray market, different gray market scenarios, and how to handle each one if discovered in a claim.

Gray Market Definition:

A Gray Market transaction is best described as hosts and guests requesting, accepting, or making payments outside of Turo.  

Why We Deny Claims and/or Void Coverage for These Items?

We deny claims following trips where we have identified, have strong evidence of, or confirmed that a Gray Market transaction has taken place due to our Terms of Service which state:

Fail to honor your commitments, including: 

• Use the Services to find a host or guest, and then complete a transaction partially or wholly independent of the Services, in order to circumvent the obligation to pay any fees related to Turo’s provision of the Services or for any other reasons (aka gray market transactions)

These types of transactions cause Turo to unknowingly provide protection and/or pay for items that have already been recovered by hosts from guests directly. Additionally, there is a greater risk of fraud and other security issues taking place when a monetary transaction is completed outside of our platform.

Gray Market transactions can also affect the way that we utilize protection and liability coverage for hosts and 3rd party vehicles. We are unable to provide coverage when it was not accurately paid for.

List of the Common Types of Gray Market Transactions:

The most common types of Gray Market transaction can be found below:

• Trip costs

• Trip extensions

• Late fees

• Delivery

• Mileage overage charges

• Reimbursement for cleaning fees

• Charges for additional products

• Tickets/Toll reimbursement

• Deposits

• Insurance or vehicle protection

How to handle a Gray Market Transaction:

Step 1: Complete your ICR and note the Gray Market item that you have identified in your ICR notes.

*Note: Do not use words or terms such as fraud, bad faith, illegal, etc. in your documentation. These are accusatory words that can hurt the company if a claim were ever to be deposed or needed to be utilized externally for a legal reason.

Step 2: Review the flow chart at the bottom of the page and follow the path specific of your scenario.

Step 3A: If the scenario calls for a denial, request authority to move forward. Include the type of Gray Market denial that you are seeking, a brief description of your investigation and findings, the evidence, and if you are also seeking to void the Guests protection too (this will be the case for gray market extensions, delivery arrangements, etc). Check with your supervisor if you need additional assistance with this item.   

Step 3B: If the scenario calls for a warning, email the host to notify them of the type of Gray Market transaction that you have identified, a brief description of your investigation and findings, and the proof or evidence that you have. Proceed with handling the claim as normal.

Step 4: Add an account flag to the reservation page using the outline below:

1. Select ‘Add a Flag’ in Dunlop.

2. Select the issue that is accurate.

3. Add the claim.

4. Add comments and submit.

Step 5: If step 3A applied, proceed with the denial process as normal if approval is received and email the host.

*Note: If this is the 2nd+ denial for a Gray Market transaction, notify your supervisor in your denial request. Hosts and guests found to be abusing this policy to the point of the initial denial being sent out will need to sign an “Agreement to Abide”.

Additional Docs to Review Related to Gray Market Denials: 

Gray Market Denial Classification Scenario Sheet

This sheet outlines the most common Gray Market scenarios that will occur along with more unique situations. It also has the routes that you should take for these situations. If you have a situation that is not listed in this sheet, please notify your supervisor in order for it to be added and a determination to be finalized for this scenario.

Gray Market Process Flow Chart