The Industry's Source for Product Providers
Jim Ganther is president of Mosaic Compliance Services. He is an attorney and a member of the National Association of Dealer Counsel.
The FTC’s proposed consent order with dealer software provider DealerBuilt settles charges relating to a major loss of customer data, but the conversation over the compliance responsibilities of ‘service providers’ — including those in the P&A segment — is just beginning.
The P&A segment must follow the same path traveled by dealers who, 15 years ago, found themselves suddenly operating under the same privacy standards as other ‘financial institutions.’
The entire industry benefits when its membership fully comprehends the legal consequences of dealer malfeasance.
In order to make any sense of what’s going on at the CFPB, we need to start at the beginning — in this case, the 2008 financial crisis and its aftermath.