I'm Chris Oday. Until recently I ran OHG Tax— federal and state tax compliance work for small businesses. The kind of practice that lives or dies on getting paperwork right and keeping people out of the wrong agency's crosshairs.
About a year ago, a friend of mine who runs a Toyota Supra A90 aftermarket performance shop was contacted by the U.S. Environmental Protection Agency. The contact wasn't dramatic. It was a letter.
He called me. We sat down and looked at what his shop had on file: a customer terms page someone had copied from a competitor, no off-road use declarations on file for the race-only components he sold, no documented procedure for handling regulatory contact, and an inventory of products on his website where the difference between “off-road competition” and “street legal” was buried in fine print no buyer ever read. He had been operating exactly the way every shop in his category operates. The problem was that the EPA's Mobile Source enforcement program had been quietly closing settlements against shops like his for over a decade, and the documents that retained counsel asks for in the first 48 hours of a regulatory matter were not on file at his shop.
I spent the next six weeks helping him build them.
That's the origin of Legal Tuning. I built fifteen documents — the Clean Air Act compliance Standard Operating Procedure, the off-road use declarations, the customer sale terms, the supplier qualification checklist, the EPA holding letter template, the litigation hold, the privacy policy under California's CCPA, the warranty reference card under the Magnuson-Moss Warranty Act, and seven others. I built them for one shop, then realized that every performance shop in the country needs the same fifteen documents and almost none of them have them. So I turned the work into an issued program.
That program is what's on this site.
What Legal Tuning does.
We issue a customized fifteen-document compliance package to performance automotive shops, record the shop in a public Member Registry, give the shop a verifiable registration number that any third party (insurer, customer, regulator) can confirm, and provide ongoing operational support if regulatory contact occurs.
We are not a law firm. The instruments are drafted to standard practice and reviewed by qualified counsel admitted in your jurisdiction before adoption. They are the framework that retained counsel will use, not a substitute for retained counsel.
Why I think this matters.
The U.S. EPA has resolved 130 Clean Air Act vehicle and engine enforcement cases against the aftermarket between fiscal years 2021 and 2025. Disclosed civil penalties total $720.5 million on file. Fiscal year 2025 alone produced $583 million in resolved settlements.
The cases that resulted in the largest aftermarket settlements all involved one or more of the same product categories the typical performance shop operates in: diesel performance modifications, catless exhaust components, ECU tunes that disable emission controls, off-road components sold without documented declarations, and multi-location distribution into California and the seventeen Section 177 states. The exposure is not theoretical and it is not evenly distributed. It is concentrated in the segment that the typical shop serves.
I built Legal Tuning to give those shops the documented compliance posture that retained counsel and insurers and regulators recognize, before regulatory contact occurs — not after, when the leverage has already shifted. Adoption of a written compliance program before contact is a recognized mitigating factor in the calculation of civil penalties under the Clean Air Act. It is also, simply, what a legitimate aftermarket business looks like.
How to start a conversation.
If your shop sells anything in the categories above and you want to see whether your current documentation matches what retained counsel will expect, schedule a call. The first conversation is free. I will tell you whether the program is right for your operation or whether you should take a different path. That recommendation is straight; I am not interested in selling you something you don't need.
— Chris Oday
Founder, Legal Tuning