What is an ITPP Program and Why Do You Need One?
June 30, 2015 by Jim Radogna
Posted in: Sales & Finance Compliance
Tags: compliance training, F&I compliance, FTC, ITTP, NCIB, red flag rule, training records
In a recent news story, an agent from the National Crime Insurance Bureau (NCIB) described how he could list dozens of cases off the top of his head in which identity thieves were able to walk into dealerships with fake identification and walk out with a car. In his words “this is the new auto theft.”
Although many identity thieves are highly sophisticated and difficult to catch, it’s vital for dealers to ensure that they are practicing due diligence in following the Red Flag Rule. The FTC hasn’t cited any enforcement actions against dealerships as of yet for Red Flags violations, but the recent spike in auto-related identity theft will likely result in dealers being targeted by the Commission. As we well know, the FTC has been very aggressive in policing auto dealers in the last few years.
In the case of a government inquiry, dealers must be able to establish that they have an Identity Theft Prevention Program (ITPP) in place, that all applicable employees have been trained on the F&I program, and most importantly, that the program is followed to the letter in EVERY transaction.
So if your dealership doesn’t have an ITPP in place yet, it’s a good time to get started. If you do have one, it’s never a bad idea to monitor the program to ensure that it’s being utilized properly and consistently.
Have questions on F&I compliance training and HR training record keeping? Call KPA today.