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dux hunt
USA
178 Posts |
 Posted - 08/14/2009 : 08:04:43
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As a P/S lender, we have been advised by our compliance department that any new dealer sign-up be required to submit a copy of their RFR's with the dealer agreement package. We don't really care what it says, but no RFR's- no sign up.
No problem I thought,that should be simple. Right! Well I've sent back at least 15-20 dealer agreements since July 1st.
I'm finding (I kid you not) that 8 of 10 P/S dealers have never heard of the RFR's. Most think it's only about ID theft and one Calfiornia dealer thought it had to do with racial profiling.
Amazing, truly amazing to me that the P/S industry is this blind to compliance. My doctor is more up on the RFR'S.
However, it get's better..... Several dealers have told me they have contacted their primary lenders and can you believe that GE and HSBC have never heard of RFR's. Freedom at least told the dealer "they think" it has to do with compliance, but could not elaborate on the subject.
Since most of us here on the Forum seem to know what's going on in regards to the RFR's, I have an idea. For our own amusement, can you P/S guys/gals call your lenders and ask if they know what the RFR's are and can they explain it. Play dumb and say you hear it might be important and would like to hear more about it.
Afterwards, report back to us about which lenders have no idea. I'll bet we'll be surprised.
JimD- have fun with this one :)
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Marv
Bahamas
7530 Posts |
Posted - 08/14/2009 : 08:26:18
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RFR/OFAC/GLB/Patriot Act and any other compliance issues are the next bastion of profit frontiers that will soon be realized by industry experts serving PS.
Marv.............
Break out the ****ing Tequila and let's all get neked.
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dux hunt
USA
178 Posts |
Posted - 08/14/2009 : 08:40:13
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| No doubt, we spent our $ to be compliant. However, you'd think the manufacture and/or lenders would at least tell their dealers to go to FTC.gov- it's free. |
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gadna50
Ireland
14378 Posts |
Posted - 08/14/2009 : 08:55:08
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I always thought red flag rules was a law passed back in 1871, it has something to do would motorcycle riders having to have a red flag on their bikes, now day's I thought it had to do with if your hauling something in a truck that hangs out over the bed or tail gate more than 4 feet you have to have a red flag stuck to it.
 
If you need help deciphering what I just wrote, Talk to the Hand.:) |
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JimD
USA
11849 Posts |
Posted - 08/14/2009 : 10:33:16
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8 of 10? You're seeing a higher, more positive response than I encountered. 95% of the PS DPs I spoke with; have no friggin clue. Worse? They have no friggin intent of compliance either.
and FTR...the manufacturers? (A) Don't give a sh*t beyond how much inventory is the store going to order and (B) How much $$ does the store owe us for sold inventory?
It is not, has not been and never was; the manufacturers job to ensure compliance. |
Edited by - JimD on 08/14/2009 10:35:16 |
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Ducati Cindy
USA
721 Posts |
Posted - 08/14/2009 : 10:58:48
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I would imagine that many of the underwriters wont know much about this. It would be something that goes through the compliance people.
For instance, when I worked at GE as an u/w, with OFAC... I knew it had something to do with a list... but never knew exactly what it was. We were never allowed to talk to the customer about it. I really only figured it out AFTER I had left.
So it seems people know, but it might be a "behind the scenes" type of thing.
I will check with some contacts at GE/FRF to see what they say.
If you think nobody cares if you're alive, try missing a couple of car payments. |
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JimD
USA
11849 Posts |
Posted - 08/14/2009 : 11:14:42
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The LENDERS know about it, but not dealership management.
Part of RFR, requires those subject to it, to ensure that all of it's "partner businesses" subject to the law are also in compliance. Only way of doing that, is to get a copy of their policy manual. (My personal opinion, is that this played a role in the mass exodus of national indirect lenders. How many dealerships did Wells Fargo have agreements with as an ex? How many copies of THEIR policy manual would they have had to distribute to how many dealers, and how many dealership policy manuals would they have had to both store AND go through to ensure compliance?) |
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Ducati Cindy
USA
721 Posts |
Posted - 08/14/2009 : 11:21:26
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quote:
Originally posted by dux hunt
However, it get's better..... Several dealers have told me they have contacted their primary lenders and can you believe that GE and HSBC have never heard of RFR's. Freedom at least told the dealer "they think" it has to do with compliance, but could not elaborate on the subject.
So whoever talked to Freedom was not talking to the right person or was confused or something. This is a letter faxed by FRF in Nov 08 to all dealers. So I fully believe they are aware.
Important Message Fax
To: FreedomRoad Dealer/Partner
Date: November 13, 2008
Subject: Red Flags and Identity Theft
This communication is being sent to you as an important reminder in regards to the recently enacted Red Flag Rules.
As you are aware effective November 1, 2008 dealerships, lenders, retail outlets, and any other business that handles customers personal information needed to be in compliance with the Fair and Accurate Credit Transaction Act of 2003 (FACT ACT). These rules require financial institutions or creditors to develop and implement an Identity Theft Prevention Program to detect, prevent, and mitigate identity theft. Included is the process of identifying and responding to RED FLAGS.
Dealers please take note of the following RED FLAGS when processing loans for FreedomRoad Financial:
Suspicious Documents and Activity
· Documents provided for identification appear to have been altered or forged.
· The photograph or physical description on the identification is not consistent with the appearance of the applicant or customer presenting the identification.
· Other information on the identification is not consistent with information provided by the person opening the account or customer presenting the identification.
· Customers conducting the transaction who do not physically appear in your dealership – all documents will need to by notarized.
You should also have a written policy in regards to safeguarding your customer’s personal information and it is your responsibility to develop and implement an identity theft prevention program.
Protect your business by safeguarding your customer’s personal information, and always be diligent in verifying your customer’s identity.
If you have any questions please feel free to call us at 866-455-7623. Thank you.
If you think nobody cares if you're alive, try missing a couple of car payments. |
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Big Coin
300 Posts |
Posted - 08/17/2009 : 15:43:55
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I would agree that it depends who you talk to when speaking with a lender.
DC
Please don't take this the wrong way as I am not bashing you, but an underwriter not knowing what OFAC is? Now that is scary... |
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fi4everish
Djibouti
1065 Posts |
Posted - 08/18/2009 : 15:01:33
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quote:
Originally posted by gadna50
I always thought red flag rules was a law passed back in 1871, it has something to do would motorcycle riders having to have a red flag on their bikes, now day's I thought it had to do with if your hauling something in a truck that hangs out over the bed or tail gate more than 4 feet you have to have a red flag stuck to it.
red flag isnt that a gay communist ?
If you need help deciphering what I just wrote, Talk to the Hand.:)
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Powersports + RFR= DISASTER!!!!
