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TOP RV DEALER FTC COMPLIANCE ISSUES

The RV Learning Center recently conducted a special webinar, "An Enhanced FTC – What Its New Investigative and Enforcement Powers Mean to RV Dealers." In this recording of the event, RVDA’s director of legal and regulatory affairs Brett Richardson summarizes current and upcoming compliance obligations and point dealers to RVDA and other resources for more information. Over the past decade, the Federal Trade Commission and Federal Reserve have rolled out regulations covering many aspects of dealer F&I compliance, such as the Safeguards, Privacy, and Red Flag Rules, as well as adverse action notices and risk based pricing notices. Click Here for a PDF of the webinar's slides. 

This web page offers links for more detailed information discussed in the webinar.

I.        PAST / CURRENT COMPLIANCE OBLIGATIONS

FTC SAFEGUARDS RULE
- RVDA Publication (RVDA member benefit, requires login)

FTC Cites Dealer For Safeguards and Privacy Rule Violations
Compliance With the FTC's Safeguards Rule

FTC PRIVACY RULE & FTC AFFILIATE MARKETING RULE - RVDA Publication  (RVDA member benefit, requires login)

FTC Model Privacy Form Builder
FTC's Privacy Rule and Auto Dealers FAQ
Agencies Issue Final Fact Act Affiliate Marketing Rule
FTC Charges First Dealer With GLB Privacy Violations
10 Ways You May Be Violating Privacy Rules

FTC ADVERSE ACTION NOTICES

Auto Dealer Monthly:  Adverse Action Notices & Here
F&I Monthly – Tackling Adverse Action Notices
Limiting Liability Under Adverse Action Notices

II.        PRESENT / RECENT FTC COMPLIANCE OBLIGATIONS

FTC RED FLAG RULES - RVDA Publication

FTC Provides a Sample RED FLAGS RULES TEMPLATE for Businesses that Self-Identify as Low Risk
CARLAW ® Compliance Series A Dealer's Guide to the Red Flags Rule ($50 online Order - and contains model Program)
CARLAW - Compliance Templates ($60 download)
Creating a Red Flags Rule Program 
FTC Business Alert - Red Flag Rules (PDF)
Anatomy of Red Flag Rule Compliance 
RV Executive Today Article on Red Flags Rules
Final Red Flags Federal Rule November 2007 (PDF)
Everything you wanted to know about the Red Flags Rule and Dealerships (external link to scanned articles in PDF)

FTC RISK BASED PRICING NOTICES / EXCEPTION NOTICES

RVDA Getting Started Info
Risked Based Pricing Q&A
FTC and Federal Reserve Issue Risk-Based Pricing Rules
New Credit Rules Decoded
FRB & FTC Issue Final Risk-Based Pricing Rule
PowerPoint Presentation Explaining Risk-Based Pricing Rules

III.         FUTURE FTC COMPLIANCE PRIORITIES AND OBLIGATIONS

DEALER SPOT DELIVERIES & DEALER LOAN MARKUPS

The FTC Hits The Road
Storm clouds gather over dealer reserve. Will regulatory pressure force switch to flat fees?
Consumer Group View on Spot Deliveries
Spot Deliveries: Pitch the Bathwater, Not the Baby
Loan Markups: Consumer Advocates Are At It Again

IV.     OTHER FTC INVESTIGATIVE ACTIVITIES

PULLING A CUSTOMERS CREDIT REPORT

The FCRA at car dealerships: the FTC’s curious conclusions about “permissible purpose”

FTC ADVERTISING TRIGGER TERMS

Regulation Z and Other Dealership Advertising Issues

More Learning Opportunities at the RV Dealers International Convention/Expo!
Don't miss a special panel discussion entitled "Straight Talk on Risk Management" on Wednesday, October 3, at the 2012 RV Dealers International Convention/Expo. The convention will be held October 1-5 at the Rio All-Suite Hotel & Casino in Las Vegas and is sponsored by RVDA–The National RV Dealers Association, RVDA of Canada, and the RV Learning Center.

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