A car dealer accepted three $1,000 checks from plaintiff car buyer as the down payment on her car.  One of the checks was post-dated by a week or two and the dealer orally agreed to delay cashing it until the date on the check.  Held, the dealer did not violate Rees-Levering by listing a full $3,000 as a cash down payment rather than disclosing $1,000 as a deferred down payment.  Nothing in Rees-Levering says that a post-dated check, even accompanied by an oral agreement not to cash it for several days is a deferred down payment—at least so long as the down payment is fully collected before the second regular installment under the contract falls due.  Nor did the oral agreement not to cash the post-dated check violate Rees-Levering’s one-document rule.

California Court of Appeal, Second District, Division 4 (Collins, J.); August 16, 2016; 2016 WL 4368157