Tag Archive | "compliance"

Senate Committee Narrowly Confirms Trump’s Pick to Head BCFP


WASHINGTON, D.C. — Kathy Kraninger, current associate director for general government at the Office of Management and Budget (OMB), was approved by the U.S. Senate Committee on Banking, Housing on Urban Affairs to lead the Bureau of Consumer Financial Protection (BCFP) by a narrow 13-12 vote.

Thursday’s vote sends President Donald Trump’s pick to head the bureau to the full Senate, which has yet to schedule a confirmation vote. If confirmed, Kraninger, who has been criticized for her lack of experience in consumer financial protection but lauded as a free-market ally in discussions about the BCFP-creating Dodd-Frank Act, would replace her boss at the OMB, Mick Mulvaney, as the bureau’s acting director.

“At her hearing, Ms. Kraninger reiterated her dedication to fulfilling the bureau’s congressional mandate, ensuring all consumers have access to markets for consumer financial products and services that are fair, transparent, and competitive,” said U.S. Sen. Mike Crapo (R-Idaho), who chairs the committee. “Given her depth and diversity of public service experience, I have the utmost confidence that she is well prepared to lead the bureau in enforcing federal consumer financial laws, protecting consumers’ sensitive personal financial information, expanding access to credit, and making the bureau more transparent and accountable.”

Kraninger, who previously worked for the Department of Transportation and was an early hire at the Department of Homeland Security, has never held public office or run a major government office or federal agency. She joined the Trump administration from the U.S. Senate Appropriations Subcommittee on Homeland Security and has served as an aide for several Senate panels.

In her role at the OMB, Kraninger helps draft budgets for seven cabinet departments and 30 government agencies totaling $250 million. That includes budgets for all financial regulators, including the CFPB.

In written testimony submitted at her July 29 nomination hearing, Kraninger emphasized that “the bureau should be fair and transparent, ensuring its actions empower consumers to make good choices and provide certainty for market participants” — goals that struck a positive chord with the financial services industry.

“The American Financial Services Association supports the Senate Banking Committee’s approval of the nomination of Kathy Kraninger as the next director of the Bureau of Consumer Financial Protection and is pleased to see her nomination pass the Banking Committee,” said Chris Stinebert, the association’s president and CEO, in a statement issued to F&I and Showroom shortly after today’s vote.

“We urge the full Senate to confirm her nomination,” he added.

Kraninger’s lack of experience, however, continued to draw criticism up until the vote, with detractors speculating that her nomination is simply a way to keep Mulvaney connected to an agency he’s worked to rein in since his appointment as acting director on Nov. 24, 2017 — the day Richard Cordray formally resigned as head of the bureau.

Kraninger has also faced questions about her role in other actions taken by the Trump administration, including its policy of separating children from their parents crossing the border and its response to the hurricanes that ravaged Puerto Rico. Also mentioned prior to the vote were reports that Mulvaney plans to suspend examinations of lenders for compliance with the Military Lending Act.

“We created the Consumer Protection Bureau to fight for average Americans, and stand up for the people we serve,” said Sen. Sherrod Brown (D-Ohio), ranking member of the Senate Banking Committee. “If there was any doubt at how important this agency is — and how damaging it can be in the wrong hands — we don’t have to look any further than Mr. Mulvaney’s outrageous actions last week, announcing that the Consumer Protection Bureau is no longer going after shady lenders that cheat our servicemembers.

“Ms. Kraninger has not spoken up and said she’ll defend our troops from payday lenders that prey on them, which speaks volumes,” he continued. “Instead we get, “I cannot identify any actions that Acting Director Mulvaney has taken with which I disagree.”

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EEOC Files Sex Bias Suit Against Ferman’s Tampa Harley-Davidson


TAMPA, Fla. — The U.S. Equal Employment Opportunity Commission (EEOC) is suing Ferman Automotive Group and Cigar City Motors, which operates Tampa Harley-Davidson and other car and motorcycle dealerships there, for discriminating against a female employee.

In its lawsuit filed on Monday in the U.S. District Court for the Middle District of Florida, Tampa Division, the EEOC alleges that Ferman violated federal law by failing to promote a female manager to general manager nine times, even though she had expressed interest, was equally or more qualified than the male candidates promoted, and was recommended to the role in at least two instances by outgoing general managers.

“The EEOC has long fought to protect women from hitting the glass ceiling in all professions and from the outdated stereotypes about women in leadership which continue to persist,” said EEOC’s Tampa Field Director Evangeline Hawthorne. “EEOC will continue to enforce the law to ensure that employers afford women the same promotional opportunities as men.”

The lawsuit also alleges that Ferman required the female sales manager, Virginia Duncan, to participate in a “mentorship” program to be eligible for promotion. The male job candidates promoted to the positions did not have the same requirement.

The EEOC filed its lawsuit after first attempting to reach a pre-litigation settlement through its conciliation process. The complaint seeks monetary and injunctive relief to address the group’s alleged discriminatory practices. Duncan and the EEOC are also asking the court to require Ferman to implement programs that offer equal opportunities for advancement to women and implement policies that prohibit gender-based discrimination.

“Although Title VII was passed more than 50 years ago, women nationwide continue to be passed over for promotion because of their sex or gender. This contributes to the gender wage gap and affects a woman’s ability to provide for themselves and their families,” said Robert E. Weisberg, regional attorney for the EEOC’s Miami District Office. “The law is clear — employers cannot discriminate on the basis of sex and they must provide a level playing field for all employees to compete for management positions.”

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FTC Charges Arizona Group With Falsifying Incomes on Consumer Credit Apps


WASHINGTON, D.C. — Three weeks after announcing the completion of a seven-state sweep regarding compliance with its Used Car Rule, the Federal Trade Commission announced on Wednesday it has charged a group of four dealerships with a range of illegal activities, including falsifying consumers’ income and down payment information on credit applications and misrepresenting financial terms in vehicle advertisements.

According to the regulator, this was the FTC’s first action alleging income falsification by dealerships. Its complaint names Richard Berry as a defendant and Linda Tate as a relief defendant. They operate a group of four dealerships in Arizona and New Mexico, near the border of the Navajo Nation.

“Buying a car is one of the biggest purchases consumers make. When consumers tell an auto dealer how much they make and how much they can pay upfront, the dealer can’t turn those facts into fiction,” said Andrew Smith, the FTC’s recently confirmed director of its Bureau of Consumer Protection. “The FTC expects auto dealers to be honest with consumers from the first advertisement to the final purchase.”

Since at least 2014, according to the complaint, Tate’s Auto allegedly increased its sales by falsifying consumers’ monthly income and down payments on credit applications and finance contracts submitted to finance sources. The four dealerships named in the complaint are Tate’s Auto Center of Winslow, Tate’s Automotive, Tate Ford-Lincoln-Mercury, and Tate’s Auto Center of Gallup.

The regulator charged that, during the sales process, Tate’s Autos asked consumers to provide personal information — including their name, address, and monthly income — and told them the information would be submitted to financing companies. But instead of using consumers’ actual information, the complaint alleges, Tate’s Auto falsely inflated the numbers, making it appear that applicants had higher monthly incomes than they really did. The dealerships also allegedly inflated the amount of a customer’s down payment.

“We’re not talking about nickel-and-dime discrepancies,” wrote Lesley Fair, senior attorney with the FTC’s Bureau of Consumer Protection, in an Aug. 1 blog post on the FTC’s website. “According to just one of the examples in the complaint, a consumer told Tate’s she had a fixed monthly income of about $1,200, but a Tate’s staffer allegedly inflated it to $5,200 in the paperwork.

“Wouldn’t consumers spot the false information? Not necessarily,” Fair continued. “The complaint charges that the defendants often used tactics that prevented people from reviewing the documents. Tate’s personnel allegedly rushed some consumers through the process; had them fill out forms over the phone or in places like grocery store parking lots or restaurants; or altered the documents after consumers signed them.”

The FTC charged that consumers, many of whom are members of the Navajo Nation, were approved for financing based on the false information the group’s dealerships provided. These consumers, the regulator further alleged, defaulted at a higher rate than qualified buyers.

The FTC also charged in its complaint that Tate’s Auto’s advertising deceived consumers about the nature and terms of financing or leasing offers. For example, the group allegedly advertised discounts and incentives without adequately disclosing limitations or restrictions that would prevent many customers from qualifying for the offers.

The regulator also alleges that Tate’s Auto’s social media ads violated the FTC Act, the Truth in Lending Act, and the Consumer Leasing Act by failing to disclose required terms. The FTC is now seeking an injunction barring the defendants from such practices in the future.

“One YouTube ad claimed the featured car ‘can be in your driveway for only $169 per month,’” Fair wrote in her blog. “In fact, consumers can’t buy that car for the advertised monthly payment. That amount applies only to a lease. What’s more, the FTC says the ad didn’t clearly disclose that to get that monthly payment, consumers must shell out $2,899 plus other fees at lease signing.

“Then there’s the online ad where the company touted an ‘incentive’ discount of $5,250,” Fair continued. “But buried behind multiple hyperlinks was the fact that the discount was available only to consumers who trade in a 1995 or newer vehicle or terminate a lease from another car company 30 days before or 90 days after delivery.”

The FTC’s complaint charges that Berry, acting as owner of the four dealerships, formulated, directed, controlled, had the authority to control, or participated in Tate’s Auto’s allegedly illegal conduct. The FTC also charges that Tate received hundreds of thousands of dollars from the other defendants, including funds directly connected to the alleged unlawful conduct.

“The complaint charges that over time, others in the industry got wise to what Tate’s was doing,” Fair wrote in her blog. “In December 2015, a major financing company that regularly worked with Tate’s conducted a review. The company reported inflated income on 17.9% of applications from Tate’s Auto Center of Gallup, 37.5% of applications from Tate’s Auto Center, 38.7% of applications from Tate’s Nissan Buick GMC, and 44.8% of applications from Tate’s Auto Center of Winslow.”

The Commission vote authorizing the staff to file the complaint was 5-0. The complaint was filed in the U.S. District Court for the District of Arizona.

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FTC, 12 Partner Agencies Conduct Used Car Rule Compliance Sweep


WASHINGTON, D.C. — The Federal Trade Commission, working jointly with 12 partner agencies in seven states, conducted the first compliance sweep of car dealerships since its amended Used Car Rule took effect earlier this year, the regulator announced today.

The sweep was conducted in 20 cities nationwide between April and June 2018. According to the FTC, inspectors found Buyers Guides on 70% of the more than 2,300 vehicles inspected, with almost half of those displaying the revised Buyers Guide. Of the 94 dealerships inspected, 33 had the revised Buyers Guide on more than half of their inventory, and 14 had revised Buyers Guides on all of their used cars.

“Why check things out now? Well, dealers were required to start using the new version of the guide on January 28, 2018,” wrote Colleen Tressler, a consumer education specialist for the FTC, wrote in a blog posted today on the regulator’s website. “And here’s what we found. Of the more than 2,325 vehicles inspected, almost half had the revised Buyers Guide. Dealers not displaying the revised guide received letters warning them to bring their dealerships into compliance.”

Under the amended Used Car Rule, which took effect on Jan. 28, 2018, dealers must display a revised window sticker, or Buyers Guide, on each used car they offer for sale. The revised guide changes the description of an “As Is” sale, places boxes on the face of the guide dealer can check to indicate whether a vehicle is covered by a third-party warranty and whether a service contract may be available, and adds airbags and catalytic converters to the Buyers Guide’s list of major defects that may occur in used vehicles, among other changes.

Dealers who fail to comply face penalties of up to $41,484 per violation. State and local law enforcement agencies also enforce the recently amended rule.

Over the coming weeks, according to the FTC, dealerships that were not displaying the revised Buyers guide can expect follow-up inspections to ensure they have brought themselves into compliance with the amended rule.

The FTC, along with its partner agencies, inspected dealership in the following areas: 1) Burbank, North Hollywood, Richmond, San Bruno, San Jose, San Pablo, and Van Nuys, California; 2) Jacksonville, Florida; 3) Chicago, Illinois; 4) New York, New York (Queens); 5) Brooklyn Heights, Cleveland, East Cleveland, and Cleveland Heights, Ohio; 6) Arlington, Dallas, and Grand Prairie, Texas; and 7) Lakewood, Puyallup, and Tacoma, Washington.

Agencies involved include the California Department of Motor Vehicles Inspection Division; district attorney’s offices in Contra Costa County, Los Angeles County, Santa Clara County, San Mateo, Calif.; the Florida Bureau of Dealer Services; the Cuyahoga, Ohio, County Department of Consumer Affairs; the Ohio Bureau of Motor Vehicles; the City of Chicago Department of Business Affairs and Consumer Protection; the New York City Department of Consumer Affairs; the Texas Department of Motor Vehicles; and the Washington State Office of the Attorney General.

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Compliance Isn’t Solely F&I’s Responsibility


Just as many in the industry operate under the mistaken impression that compliance is just an “F&I thing,” many also operate under a similar mistaken impression that agents only help with training and assistance in the F&I office. I know many agents who spend a fair amount of time with sales managers on “road-to-the-sale” processes that affect compliance. If your agency offers sales process training, there are some compliance issues that either start or germinate in sales that you should be aware of.

The findings in our compliance consulting practice confirm that the majority of compliance concerns either start in sales or germinate during the sales process. Somehow, some way, the idea that compliance in the variable process has been pegged as “F&I compliance” is prevalent and misleading.

The fact that a majority of compliance issues are sales-related should not shock your system. Only one of the 10 steps on the road to the sale process takes place in F&I. Steps One through Eight are sales responsibilities. Step Nine is the F&I turnover, then back to sales for delivery.

Many touchpoints along the road to the sale with the consumer present a potential requirement to conform to a state or federal law or statute. Many other touchpoints require an employee to subscribe to dealer law to avoid a
deceptive practice.

Let’s look at the sales touchpoints in a 10-step “Road to the Sale” process:

1. Meet and greet: Not much here from a compliance perspective. Granted, it is bad business to greet a consumer with bad breath, matted hair and wrinkled clothes, but these are certainly not compliance concerns. In fact, there probably will not be any compliance concerns if the consumer walks away immediately.

However, consumer questions about the advertised price, a price quoted in a website, or factory incentivized financing may creep into the discussion.

2. Interview: This is the needs-assessment step. Most dealers want to discover the consumer’s desires, so there should not be any gathering of nonpublic personal information (NPI), credit applications or trade-in specifics.

Some consumers may offer up information about a bad credit history or being upside down in a trade. Some veteran salespeople may then skip some of the “road to the sale” steps. They figure out that this consumer cannot buy or finance a vehicle and send them packing. The consumer must be given a privacy notice if this wily old dog has gathered NPI. Or, if the consumer signed a five-liner to pull credit, an adverse action notice is required.

What if the wily old dog figured out quickly that the consumer is a subprime candidate and moves to step three? The consumer is led to a used vehicle with a potential fee added to the sale price.

3. Vehicle selection: Potential compliance pop-ups inherent to this step including handling a subprime fee, CPO warranty or fees, and advertised price.

4. Walkaround: After the consumer selects a vehicle, the salesperson walks the consumer around the vehicle, pointing out the features, benefits and differences from competitive makes. During this walkaround, there may be questions about labeling on new vehicles such as the Monroney label or dealer addendum.

On a used vehicle or prior demonstrator, the used car buyer’s guide must be prominently displayed. A used vehicle may also be plastered with a “Certified” sticker, which may raise questions about CPO warranties or — heaven forbid — adding a CPO fee to a non-CPO vehicle.

If the discussion between salesperson and consumer for a used vehicle in Steps One through Four have been in Spanish, a Spanish-language buyer’s guide is required.

5. Test drive: A salesperson is usually instructed to gather up driver’s license and insurance information before the consumer is permitted to get behind the wheel. Gathering and copying the driver’s license is usually the first piece of NPI obtained by the salesperson. This triggers the federal requirement to provide the consumer with the dealership’s privacy notice.

Some dealers prefer to wait until the consumer becomes a customer and deliver the privacy notice in F&I. Assuming a 25% closing ratio, this means that three-quarters of required privacy notices are not provided.

6. Trade evaluation: Part of the trade evaluation must take current recalls, prior use, prior damage and branded titles into account. While pulling Carfax, AutoCheck, NMVTIS and SaferCar.gov searches are not a compliance requirement on a trade-in, they can certainly provide much-needed information on the value of the trade.

7. Present numbers and ask for the sale: This is the where the compliance concerns heat up. Potential pitfalls include accepting credit applications, pulling credit bureau reports, desking deals, powerbooking, providing credit score disclosure notices, running OFAC, dealer doc fees, factory incentives, and making a copy of a military ID.

8. Close: The close is where creative sales managers can revert to “Wizard of Oz” mode, sitting at the tower instead of behind a curtain. Sometimes, to close deals, a sales manager will resort to old-school tricks such as developing a deferred down payment plan, incorporating cash back to the customer, structuring a straw purchase, or requiring a backup contract be executed with a different down payment.

9. F&I turn: The F&I manager firms up the paper trail execution — including final pencil, menu, buyer’s order, RISC or lease, and product enrollment forms — and acts as the backup checker to make sure sales did everything it was supposed to do.

10. Delivery and service drive intro: Most of the dealer’s compliance requirements have been met with their newest customer. Potentially, though, the salesperson may start mining this new customer for prospects. Armed with the neighbor’s or relative’s name, address, phone, fax and cell numbers, the salesperson may ignore do-not-call lists or CAN-SPAM requirements.

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Phil Gramm, Jim Leach, Tom Bliley, and You


Compliance Questions

  • Would you like to be subjected to a potential fine of $41,484 per day?
  • Or enter into a 20-year consent judgment where you are subject to biannual audits?
  • Would you like to be subjected to as much as a $50,000 statutory penalty per violation?
  • Or pay legal fees, costs, and damages for breaches of contract or negligence claims that could run into the millions of dollars?

Answering These Questions in the Affirmative

If any of these results seem attractive to you, then haphazardly download great quantities of data from your dealer management system, especially nonpublic personal information (NPI), place it where other people can access it, or, better yet, share it with everyone. You and the dealership will face these consequences.

The Relevant Law Guiding these Results

Today, in 2018, it is only a footnote for the automotive industry that the Financial Services Modernization Act of 1999, better known as the Gramm-Leach-Bliley Act, or GLBA — named after its progenitors, Senator Gramm and Congressmen Leach and Bliley — was enacted to eliminate the Glass Steagall Act of 1933 which, in this author’s viewpoint, was a legislative error. Banks, brokerage firms, and insurance carriers were prohibited from merging under the Glass-Steagall Act, which prevented the concentration of capital.

GLBA repealed this law so that these types of institutions can merge. But two elements of the GLBA are relevant to people in the automobile industry: the Privacy Rule and the Safeguards Rule.

The Privacy Rule: As the name implies, privacy is the issue. When a consumer relationship begins, the dealer must provide a privacy notice to that consumer. There are almost 300 variations of these notices which must tell the consumer how data is collected, shared, used, and protected. In addition, there must be an option provided to the consumer by which he can opt out of any sharing of his data with third parties. This notice must be provided annually. The model privacy form, can be found at: http://www.ftc.gov/privacy/privacyinitiatives/PrivacyModelForm.pdf.

The Safeguards Rule: The Safeguards Rule is the corollary of the Privacy Rule. As one should recognize, dealers are creditors and, as such, must develop a written security plan detailing how the dealership is protecting consumer data. A compliance officer should be appointed to oversee these safeguards. A dynamic plan should be developed which addresses the risk, with designed and tested programs redressing this risk, and reevaluations for changes in the plan as the nature of the business evolves. Encryptions, firewalls, passwords, locked vaults, and desks are examples of safeguards.

Access to Data in the Dealer Management Systems (DMS)

Reckless dealers will allow free access to the data stored in the DMS. And reckless F&I managers will access this data with abandon if given the opportunity. A sophisticated DMS will only provide data to personnel at the store commensurate with their job status and need. In other words, the general manager will have greater access to the stored data than an F&I manager.

User access to data should be reviewed and updated continuously as the Safeguards Rule requires. In DMS parlance, “PII” is being protected. PII is personally identifiable information — any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used to solve for anonymous data can be considered PII. NPI is the acronym from GLBA itself for “personally identifiable financial information” and is similar in concept to the PII. Private consumer information, which is not readily available, would be considered NPI. It is “derived using any personally identifiable financial information” that is “not publicly available.”

What Must be Done 

GLBA was passed in 2003 so it would be astounding if a dealer hadn’t already complied with its requirements and continues to do so. It is important to emphasize that the Safeguards Rule must be dynamic and continually updated. Anyone who works at the store should consult this written plan. As the organization evolves, these changes should be expressed in the written plan. This plan should include certain basic protocols for keeping consumer information secure and confidential, such as:

  • Locking rooms and file cabinets where records are kept;
  • Not sharing or openly posting employee passwords in work areas;
  • Encrypting sensitive consumer information when it is transmitted electronically via public networks;
  • Referring calls or other requests for consumer information to designated individuals who have been trained in how your company safeguards personal data; and
  • Reporting suspicious attempts to obtain consumer information to designated personnel.
  • Ensure that storage areas are protected against destruction or damage from physical hazards, like fire or floods.
  • When consumer information is stored on a server or other computer, ensure that the computer is accessible only with a “strong” password and is kept in a physically secure area.
  • Where possible, avoid storing sensitive consumer data on a computer with an internet connection.
  • Maintain secure backup records and keep archived data secure by storing it offline and in a physically secure area.
  • Maintain a careful inventory of your company’s computers and any other equipment on which consumer information may be stored.
  • Copiers and fax machines may keep records of all documents which have been copied and faxed. These electronic files should be completely deleted before discarding or returning this equipment.
  • When you transmit credit card information or other sensitive financial data, use a Secure Sockets Layer (SSL) or other secure connection, so that the information is protected in transit.
  • If you collect information online directly from consumers, make secure transmission automatic. If you must transmit sensitive data by email over the internet, be sure to encrypt the data.
  • Dispose of consumer information in a secure way and, where applicable, consistent with the FTC’s Disposal Rule. This means one must burn, pulverize, or shred papers containing consumer information so that the information cannot be read or reconstructed.
  • Destroy or erase data when disposing of computers, disks, CDs, magnetic tapes, hard drives, laptops, PDAs, cell phones, or any other electronic media or hardware containing consumer information.
  • Check with software vendors regularly to get and install patches that resolve software vulnerabilities;
  • Use anti-virus and anti-spyware software that updates automatically;
  • Maintain up-to-date firewalls, particularly if you use a broadband internet connection or allow employees to connect to your network from home or other offsite locations;
  • Regularly ensure that ports not used for your business are closed; and
  • Promptly pass along information and instructions to employees regarding any new security risks or possible breaches.
  • Keep logs of activity on your network and monitor them for signs of unauthorized access to consumer information;
  • Use an up-to-date intrusion detection system to alert you of attacks;
  • Monitor both in- and outbound transfers of information for indications of a compromise, such as unexpectedly large amounts of data being transmitted from your system to an unknown user; and
  • Insert a dummy account into each of your consumer lists and monitor the account to detect any unauthorized contacts or charges.

Should a breach occur in spite of your best efforts the following steps should be implemented:

  • Take immediate action to secure any information that has or may have been compromised.
  • Preserve and review files or programs that may reveal how the breach occurred; and
  • If feasible and appropriate, bring in security professionals to help assess the breach as soon as possible.
  • Notify consumers if their personal information is subject to a breach that poses a significant risk of identity theft or related harm;
  • Notify law enforcement if the breach may involve criminal activity or there is evidence that the breach has resulted in identity theft or related harm;
  • Notify the credit bureaus and other businesses that may be affected by the breach.
  • Check to see if breach notification is required under applicable state law.

Compliance Questions Explained

The Federal Trade Commission (FTC) enforces the Privacy Rule and Safeguards Rule against franchise dealers. Its regulatory penalty for violations is $41,484 per day. Certain independent and BHPH dealers will be disciplined by the CFPB.

These two rules don’t specifically allow for individual claims. However, this is not a problem for plaintiffs since violating the GLBA is considered a violation of the state’s Unfair and Deceptive Trade Practices Act (UDAP) which means both state attorneys general and consumers can file lawsuits for these types of violations. In the state of Illinois, for example, the UDAP statutory damage amount is $50,000 per incident.

Furthermore, common law also provides a cause of action, should a dealership and F&I manager fail to carefully safeguard consumers’ NPI. This legal theory is the tort of negligence. A negligence claim has these elements:

  1. The defendant (dealer and/or F&I manager) has a duty to the consumer to keep the data secure;
  2. The defendant breached this data security duty;
  3. This breach was the cause of the consumer’s injury; and
  4. The consumer suffered damages because of the defendant’s breach of its data security duty.

Finally, many contracts include language which addresses the privacy and safeguards of consumer data. If such a contract is materially breached consumers can sue the dealer and you.

The privacy and safeguarding of a consumer’s data is a solemn responsibility. Dealers and all dealer employees need to be cognizant of these responsibilities.

Govern yourselves accordingly.

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