Staying Compliant While Working Remotely
The rapidly changing circumstances around the COVID-19 pandemic are forcing dealerships to adapt quickly. In areas where shelter-in-place or stay-at-home orders have led to closed showrooms, some dealership personnel have relocated to their home offices to continue their work.
As dealerships create new guidelines and processes to keep in touch with their customers during this period, it’s important to ensure that regulatory compliance is built into those plans. Here are some suggestions to help protect your dealership:
Make Compliance A Priority
Be sure to think through and create a plan for compliance considerations that could be more challenging outside the dealership. Consult with your legal counsel to make sure your business continuity procedures account for continued compliance.
Keep Customer and Deal Data Safe
Many consumer protection laws are based on safeguarding customers’ personally identifiable information (PII). When working remotely, it’s important to conduct business using secure, encrypted Wi-Fi when accessing software solutions and communicating with customers, dealership staff members, lenders and other partners.
Observe FTC Marketing Restrictions
There are lots of options for keeping in touch with your customers today, including text messages, emails, phone calls, video chats and more. However, just because you have someone’s contact information doesn’t mean you can market to them without their consent. Anyone on a “do not call” list – whether federal, state or internal to your dealership – is off limits for marketing messaging.
While technology can be very useful for keeping the lines of communication open for active leads and deals in progress, make sure to observe the legal boundaries.
Avoid Fraud Attempts
It’s an unfortunate reality that criminals will take advantage of a crisis. The FTC has issued a warning about identity theft scams that use COVID-19 as a pretext, so have your staff stay alert for phishing attempts. To protect your dealership and your customers, continue to be vigilant about running OFAC checks and Red Flag alerts – and use out-of-wallet questions as needed to verify customer identity.
Make Compliance Part of the Deal Closing
It’s the dealer’s responsibility to deliver the final signed copy of the contract to the customer at the conclusion of the deal. When choosing an eSigning solution that allows for remote contract review and signing, make sure you can fulfill this important compliance step.
Need more tips? Register for the all-digital 2020 Dealertrack Compliance Guide to use as a reference for maintaining compliance.