Dealer Reinsuranceby Elite FI Partners
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Structure comparison

DOWC vs CFC: Owning the Warranty Company or Reinsuring Offshore

A DOWC and a CFC are both companies a dealer owns, but they do different jobs. A CFC reinsures products another company issues. A DOWC is the company that issues the product. That one difference drives the rest: domicile, licensing, capital, administration, and how far the structure can scale. This page lays out the comparison using the facts in the DOWC and CFC guides.

Quick answer

A CFC is an offshore reinsurance company the dealer owns that reinsures F&I products another company issues, often under an 831(b) election that caps annual premium. A DOWC is a domestic U.S. C-corporation the dealer owns outright, licensed as a service contract provider, that issues its own branded contracts with no premium cap. The CFC asks for less capital, licensing, and administration; the DOWC asks for more in exchange for brand ownership and more direct control.

What you'll learn
Side by side

DOWC and CFC compared.

The table summarizes the differences dealers ask about most. It is a general guide drawn from the structure pages on this site. State requirements, program documents, and your own advisors decide the details.

FeatureDOWCCFC
OwnershipSolely owned by the dealer or dealer groupDealer owned
DomicileDomestic U.S. C-corporationOffshore, while meeting IRS requirements
What it doesIssues its own branded contractsReinsures products another company issues
ControlOwner designs products, pricing, and claims philosophy and chooses the administratorOwner controls the company and directs reserve investments
Who holds the riskThe DOWC, as the warranty company; no premium is ceded outThe CFC assumes the risk on ceded premium
Tax treatmentFederal corporate rates; possible early-year deferral depending on circumstances; distributions taxed againMany programs use an 831(b) election; eligibility is a professional determination
Premium capacityNo annual premium capWith an 831(b) election, bounded by the annual cap
Capital and licensingState minimum capital plus operating reserves; service contract provider license in each stateMust be properly capitalized; amount depends on domicile and administrator
Setup timeRoughly four to six months, per the DOWC guideTypically a few weeks once the plan is agreed, per the CFC guide
AdministrationHighest: own books, audit, statutory reporting, governanceModerate: reporting, audits, tax filings, offshore administration
Typical fitHigh-volume dealers and groups wanting their own brandMid-volume stores at or under the cap
Exit and successionSeparate operating company; can continue, be wound down, or be transferredSeparate asset; can continue, be wound down, or be transferred

The 831(b) premium cap is $2.9 million for tax years beginning in 2026, per IRS Revenue Procedure 2025-32. It is indexed for inflation and set annually, so confirm the figure for the relevant tax year with your tax advisor. Capital amounts for either structure depend on domicile, states, and product mix and are confirmed in a pro forma.

CFC

When a CFC fits better.

A CFC is the lower-friction way to own underwriting results. It may be the better fit when:

  • Qualifying premium is at or under the 831(b) cap.
  • The dealer wants ownership of reserves and investment income without operating a licensed warranty business.
  • The dealer is content to sell an administrator’s product rather than its own brand.
  • Lower capital, lighter compliance, and a shorter setup matter more than brand control.
  • The dealer has never run a captive and wants to learn the economics first.

The CFC guide covers the mechanics and the planning considerations in full.

DOWC

When a DOWC fits better.

A DOWC asks more of the dealer and gives more control in return. It may be the better fit when:

  • The dealership or group has outgrown the 831(b) cap and wants no ceiling on participation.
  • The owner wants a branded warranty as a customer retention asset.
  • The dealer wants to set product terms, pricing, and claims philosophy directly.
  • A domestic structure matters, without offshore administration.
  • The owner is prepared for state licensing, surety bonds, statutory reporting, and its own audit.
  • The group has already run a CFC or Super CFC and knows what its stores produce.

The DOWC guide explains the products a DOWC can write and why administrator selection matters.

Transition

Moving from a CFC to a DOWC.

The structure pages describe a path that often runs from a CFC toward a DOWC as production grows. The step is large because it changes what the company is, from a reinsurer of someone else’s product to the issuer of your own. Plan for:

  • The licensing runway. Service contract provider licensing in each state where you sell sets the timeline.
  • Capital. State minimum capital plus operating reserves, confirmed against the states where you sell.
  • Administration. A stand-alone C-corporation needs its own books, audit, governance, and statutory reporting.
  • The existing CFC. Ask for written treatment of its reserves and open claims before changing where new production goes.

If the main reason to leave a CFC is the cap, a Super CFC also removes the annual limit with lower setup friction. The DOWC guide describes the Super CFC as the midpoint between the two; see Super CFC vs DOWC.

Due diligence

Questions to ask before choosing.

Bring these to any provider and to your own advisors, and ask for the answers in writing:

  • Is my qualifying premium near or past the 831(b) cap?
  • Do I want my own warranty brand, or is reinsuring an administrator’s product enough?
  • In which states would a DOWC need to be licensed, and what capital do they require?
  • Who would administer claims, and how does that administrator report?
  • Who controls the reserves and how they are invested in each option?
  • What is the full, itemized fee schedule for each option?
  • What ongoing accounting, audit, and filing work would I take on?
  • What do my tax advisors conclude about the treatment of each option?

A fuller checklist is on the questions to ask page.

FAQ

Frequently asked questions.

What is the difference between a DOWC and a CFC?

A CFC is an offshore reinsurance company the dealer owns that reinsures F&I products another company issues, and many CFC programs use an 831(b) election that caps annual premium. A DOWC (Dealer-Owned Warranty Company) is a domestic U.S. C-corporation, licensed as a service contract provider, that issues the dealership’s own branded contracts with no annual premium cap. The CFC asks for less capital, licensing, and administration; the DOWC asks for more.

Is a DOWC a form of reinsurance?

Not in the same sense. A reinsurance structure such as a CFC participates in a product someone else owns and issues. A DOWC owns and issues the product itself, so there is no separate product owner to cede premium to. It sits at the control end of the range of dealer participation structures.

How is each structure taxed?

A DOWC is taxed as a domestic C-corporation at federal corporate rates. Unearned premium accounting may provide opportunities for income deferral in the early years depending on a dealership’s circumstances, and distributions add a second layer of tax. Many CFC programs use an 831(b) election. In both cases, the treatment for a specific company is a determination for qualified tax advisors.

How long does each take to set up?

The CFC guide describes a CFC as typically a few weeks to form once the pro forma and product plan are agreed. The DOWC guide estimates roughly four to six months from decision to the first contract written, because service contract provider licensing in each state takes time.

Does a DOWC have a premium cap?

No. Unlike a CFC using the 831(b) election, a DOWC has no annual written premium limit, so it scales with production. A CFC using the election is bounded by the annual cap.

Should a dealer start with a DOWC instead of a CFC?

Usually not. A DOWC is rarely a dealer’s first move. Stores at or under the 831(b) cap, owners who need immediate cash flow, and dealers who have never run a captive are generally better served by a CFC, Super CFC, or Retro program first. Many dealers who reach a DOWC have already run a CFC or Super CFC and know what their stores produce.

What happens to each if I sell my dealership?

Both are separate companies from the dealership. In most cases either can continue, be wound down, or be transferred independently of a dealership sale. A DOWC with contracts in force is also an operating business with its own brand, which can matter in succession planning.

Educational notice

This page is for education only and is not tax, legal, or accounting advice. Tax treatment, licensing and capital requirements, and structure fit depend on each dealership’s facts, the states involved, and the rules in force, so review any decision with qualified tax, legal, and accounting professionals.

Recommended resources
When you want a second look

Request a reinsurance review.

Elite FI Partners can compare a CFC and a DOWC on your dealership’s actual production, states, and goals, alongside your own tax and legal advisors. The review is meant to show the full picture, and it will not always recommend a change.

Request a reinsurance review