Dealership Risk Assesment

DO YOU OVERSEE YOUR SERVICE PROVIDERS FOR HOW THEY PROTECT YOUR CUSTOMER'S INFORMATION?*

DO YOU CONDUCT PHISHING TESTS AS PART OF YOUR STAFF’S SECURITY AWARENESS TRAINING?

HAVE YOU CONDUCTED AN AUDIT OF YOUR SAFEGUARD POLICY/PROCEDURE IN THE LAST 12 MONTHS?*

DO YOU HAVE A QUALIFIED SINGLE INDIVIDUAL NAMED TO OVERSEE YOUR DEALERSHIP’S INFORMATION SECURITY PROGRAM?

DO YOU USE THE FTC BOILERPLATE FOR YOUR PRIVACY POLICY?*

DO YOU CHECK ALL CASH, FINANCE AND LEASE CUSTOMERS AGAINST THE OFAC LIST BEFORE YOU COMPLETE THE DEAL?*

DO YOU KNOW HOW TO CONTACT OFAC?*

DOES YOUR F&I DEPARTMENT COMPLETE THE FIRST PORTION OF THE 8300 FORM?*

DO YOU NOTIFY THE IRS WITHIN 15 DAYS OF THE COMPLETION OF THE 8300 FORM?*

DO YOU CHECK EACH PROSPECT'S TELEPHONE NUMBER AGAINST THE DO NOT CALL LIST 31 DAYS AFTER THEIR LAST TELEPHONE CALL TO YOUR DEALERSHIP?*

DO YOU REMOVE THE CUSTOMER FROM YOUR EMAIL CAMPAIGN WITHIN 10 DAYS OF THEIR REQUEST?*

DO YOU HAVE A FORMAL RATE MARK UP POLICY, WHICH IS USED WHEN DESKING DEALS?*

DO YOU DOCUMENT EACH DEAL WHEN YOU NEGOTIATE DOWN YOUR INTEREST RATE USED IN A DEAL?*

DO YOU ALWAYS GET A SIGNED CREDIT APPLICATION BEFORE YOU RUN CREDIT?*

DO YOU PROVIDE YOUR CUSTOMER AN ADVERSE ACTION NOTICE WITHIN 30 DAYS WHEN THEY CAN'T GET FINANCED OR DON'T ACCEPT A COUNTER OFFER?*

DO YOU PROVIDE EACH FINANCE CUSTOMER A COPY OF A CREDIT SCORE DISCLOSURE NOTICE?*

DO YOU VERIFY AND VALIDATE THE IDENTITY OF EACH FINANCE CUSTOMER BEFORE YOU COMPLETE THE DEAL?*

DO YOU PROVIDE A BLANK COPY OF THE RETAIL FINANCE CONTRACT TO THE CUSTOMER TO REVIEW BEFORE COMPLETING THE CONTRACT?*

DO YOU FULLY DISCLOSE ALL THE ITEMS IN THE "FEDERAL BOX" ON THE CONTRACT TO THE CONSUMER, BOTH, IN WRTING AND ORALLY BEFORE CONSUMMATING THE CONTRACT?*

DO YOU PROVIDE THE CONSUMER WITH A COMPLETED, SIGNED COPY OF THE RETAIL FINANCE CONTRACT AFTER THEY SIGN THE CONTRACT?*

FOR DESKING DEALS, DO YOU USE A 90 DAY ROLLING AVERAGE OF YOUR RATES AND TERMS FOR EACH CUSTOMER?*

DO YOU DISCLOSE THE COSTS AND TERMS OF EACH LEASE WITH THE CUSTOMER BEFORE THEY SIGN THE CONTRACT?*

DO YOU HAVE WRITTEN POLICIES AND PROCEDURES FOR THE FEDERAL LAWS THAT GOVERN YOUR DEALERSHIP?*

DO YOU HAVE A DOCUMENTED TRAINING PROGRAM IN PLACE FOR ALL YOUR EMPLOYEES FOR THE FEDERAL LAWS THAT GOVERN FOR YOUR DEALERSHIP?*

DOES YOUR STAFF’S SECURITY AWARENESS TRAINING INCLUDE THE PHYSICAL SECURITY OF OFFICES, FILES AND COMPUTERS?