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.
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.
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.
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.
| Feature | DOWC | CFC |
|---|---|---|
| Ownership | Solely owned by the dealer or dealer group | Dealer owned |
| Domicile | Domestic U.S. C-corporation | Offshore, while meeting IRS requirements |
| What it does | Issues its own branded contracts | Reinsures products another company issues |
| Control | Owner designs products, pricing, and claims philosophy and chooses the administrator | Owner controls the company and directs reserve investments |
| Who holds the risk | The DOWC, as the warranty company; no premium is ceded out | The CFC assumes the risk on ceded premium |
| Tax treatment | Federal corporate rates; possible early-year deferral depending on circumstances; distributions taxed again | Many programs use an 831(b) election; eligibility is a professional determination |
| Premium capacity | No annual premium cap | With an 831(b) election, bounded by the annual cap |
| Capital and licensing | State minimum capital plus operating reserves; service contract provider license in each state | Must be properly capitalized; amount depends on domicile and administrator |
| Setup time | Roughly four to six months, per the DOWC guide | Typically a few weeks once the plan is agreed, per the CFC guide |
| Administration | Highest: own books, audit, statutory reporting, governance | Moderate: reporting, audits, tax filings, offshore administration |
| Typical fit | High-volume dealers and groups wanting their own brand | Mid-volume stores at or under the cap |
| Exit and succession | Separate operating company; can continue, be wound down, or be transferred | Separate 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.
A CFC is the lower-friction way to own underwriting results. It may be the better fit when:
The CFC guide covers the mechanics and the planning considerations in full.
A DOWC asks more of the dealer and gives more control in return. It may be the better fit when:
The DOWC guide explains the products a DOWC can write and why administrator selection matters.
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:
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.
Bring these to any provider and to your own advisors, and ask for the answers in writing:
A fuller checklist is on the questions to ask page.
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.
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.
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.
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.
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.
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.
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.
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.
How a dealer-owned warranty company works.
How a dealer-owned offshore reinsurer works.
Retro, CFC, Super CFC, NCFC, and DOWC side by side.
Weigh the options against your goals.
Model the numbers on your own production.
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.