Privacy and Patriot Acts

Question 1

Under the Privacy Act, dealers have been declared “Financial Institutions”. Therefore:

Answer 1

 They must safeguard customers’ non-public personal information.
 They must produce a plan, in writing, outlining the dealership’s plan to safeguard
the customer’s information.

Question 2

If the customer has a current loan with the dealer:

Answer 2

 The privacy policy is sent annually during the same month each year to those
customers who will owe the dealership payments after the month of the mailing.

Question 3

The dealer must give a customer a privacy notice no later than at the time of signing the retail installment contract or lease agreement. (T/F)

Answer 3

 True.

Question 4

A dealer must check the “Blocked Persons” list published by the Office of Foreign Asset Control (OFAC) to ensure the customer is not a person on the list before entering a cash or credit transaction with the customer. (T/F)

Answer 4

 True.