- Adopt clear, written policies for taking online credit applications.
- Set the Web site to provide click-through authorization before the customer can proceed with online credit application.
- Use encryption technology to make sure transmission of the credit application is secure.
- Never let dealership employees ask customers to submit credit applications or other personal information over insecure media such as e-mail.
- Never share credit information with customers until they arrive at the dealership and present proof of their identity.
- Have customers complete and sign a hard copy of a credit application in person even after they give authorization online. At the time they complete the application, provide them with a copy of the dealership’s privacy policy.
- Mail a copy of the dealership’s privacy policy to consumers who decided not to buy a vehicle.
- Mail an adverse action notice to consumers if the dealership can’t obtain financing for them.
- Mail customers a credit score disclosure within two days after pulling the credit report to comply with the federal Risk-Based Pricing Rule.Be sure to mail the disclosure to the current address shown on the credit report, rather than the unverified address on the credit application.
- Don’t mail the credit score disclosure if customers clearly withdraw their credit application