TLDR:
DealerRefresh has been working to educate dealers and vendors on the FTC Safeguards and Gramm-Leach-Bliley Act. We have worked with NADA and NIADA on this. We have spoken to consultants (including Tom Kline) and attorneys who help businesses create a definition for their own interpretation of these changes.
There are a lot of misinformed people out there. In our last RefreshFriday with Tom Kline, we rated the readiness of the automotive industry, and on a scale of 1-10, we rated our industry a 3.
I have encountered dealerships who thought they would have to eliminate all their vendors. Others believe they can't quote a customer a price or payment anymore or show pricing on their website. This thread is an attempt at curbing this kind of fear.
Here are some simple ways to get started on documenting how you plan to comply with these new rules:
The name of the game is identifying what areas might be subject to these new rule changes and planning how and when you think you can comply based on your interpretations of these rules today.
I fully anticipate specific definitions will be made through legal battles. If you are the subject of that, you're going to get familiar with things quickly. But it is hard to punish someone who is making an effort to comply... hence, the identifying and planning.
Here are more resources to help you:
forum.dealerrefresh.com
forum.dealerrefresh.com
forum.dealerrefresh.com
forum.dealerrefresh.com
- nobody knows every specific of a new government rule - specifics should later come out of court cases
- document everything - have a written document showing how you are trying to comply just in case the FTC knocks on your door
DealerRefresh has been working to educate dealers and vendors on the FTC Safeguards and Gramm-Leach-Bliley Act. We have worked with NADA and NIADA on this. We have spoken to consultants (including Tom Kline) and attorneys who help businesses create a definition for their own interpretation of these changes.
There are a lot of misinformed people out there. In our last RefreshFriday with Tom Kline, we rated the readiness of the automotive industry, and on a scale of 1-10, we rated our industry a 3.
I have encountered dealerships who thought they would have to eliminate all their vendors. Others believe they can't quote a customer a price or payment anymore or show pricing on their website. This thread is an attempt at curbing this kind of fear.
Here are some simple ways to get started on documenting how you plan to comply with these new rules:
- Identify all the places you show a price or payment.
- Identify where you collect or farm a customer's email address, phone number, and/or physical address.
- If an outside vendor is involved with any of those places, contact the vendor for a written explanation of their plan for complying with the FTC changes and hold onto all those responses.
- If you are the one hosting one of those forms or calculating and showing price/payment, you will need to come up with your own interpretation of the FTC rules and develop a plan to comply.
- If your sales agents talk about pricing or collect customer information, you will need to come up with your own interpretation of the FTC rules and develop a plan to comply.
The name of the game is identifying what areas might be subject to these new rule changes and planning how and when you think you can comply based on your interpretations of these rules today.
I fully anticipate specific definitions will be made through legal battles. If you are the subject of that, you're going to get familiar with things quickly. But it is hard to punish someone who is making an effort to comply... hence, the identifying and planning.
Here are more resources to help you:
A Dealer Guide to the FTC Safeguards Rule - Download PDF
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