Dealer Checklist for Compliance
The Dealer's Association is here for many reasons. One of which is to inform you in advance regarding important industry changes. Many dealers on a national level are being targeted by plaintiff's attorneys on simple compliance issues. The expense is so great; we can no longer ignore our responsibilities as a dealer body. Please review the checklist below and appoint one key employee responsible for compliance immediately.
Dealer Checklist for Compliance
Give the consumer a copy of your privacy policy immediately after you receive any personal information whatsoever.
Obtain permission and a signature from the consumer before accessing their credit file. Store the signature in a secure location.
Run an OFAC and Red Flags check on all consumers and verify identity before entering into a business relationship.
Immediately shred any and all discarded personal information.
Make sure that all employees are aware of and acknowledge in writing to adhere to your Information Security Program.
Never leave any personal information exposed or in a non-secure location.
Spot check deal jackets to confirm employee compliance to written company policy.
All electronic personal private information must be password protected. All hard documents must be stored in a secure location.
Regularly include risk assessment in management meetings.
Send a notice of adverse action to all consumers who unsuccessfully request an extention. of credit. Store in a secure location for at least 5 years.
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