2017 GNYADA Membership Directory

HOT TOPICS

FEDERAL RULES TO FOLLOW

IDENTITY THEFT PREVENTION COMPLIANCE Red Flags Rule - Dealers must detect, prevent and mitigate identity theft - Perform Risk Analysis - Develop Identity Theft Protection Program (ITPP) - Penalty: up to $16,000 per violation Address Discrepancy Rule - Establish policy and procedure to confirm credit applicant’s identity Safeguards Rule - Ensure security and confidentiality of customers’personal information - Implement safeguards program detailing how your dealership will safeguard and dispose of consumer information OFAC (Office of Foreign Assets Control) Rule - Prevents dealers from conducting business with those on SDN (specially designated nationals) and blocked persons list - Run OFAC check on every customer - Penalties: Fines up to $10 Million, civil penalties up to one million dollars per violation, plus imprisonment up to 30 years CREDIT COMPLIANCE Risk Based Pricing Notice - Required disclosure notice to consumers who receive credit on less favorable terms than the terms received by a proportion of other credit customers - Provide Credit Disclosure Exception Notice to ALL consumer credit applicants - Penalty: settlement civil penalties up to $3,500 per knowing violation Adverse Action Notice - Notice required when consumer is refused credit or if credit is offered and refused by consumer at a less favorable rate than the consumer sought (counter-offer) - Send notice within 30 days of receiving completed credit application OR within 90 days of making counter- offer which your consumer rejects

MEMBERSHIP

DIRECTORY

2017

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