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Seven Deadly Sins of F&I
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Red Flag Program for Dealers
While dealers must be in full compliance with the Red Flag Rule by
November 1, 2008, somewhere in the middle of this, we need to sell some
cars. In response to the pending legislation, AFIP has released The F&I Manager’s Guide to the Red Flag
material isn’t legal advice – it’s practical instructions to develop a
program that fits into your dealership’s operations without requiring
additional paperwork for F&I managers. The guide is available
to AFIP Industry Members, AIGA members, and dealers.
The GUIDE Includes:
- A complete overview of the Red Flag Rule and the
policies and procedures needed to meet the standards it imposes
- Modifiable templates (on CD) to tailor you
dealership’s Identity Theft Prevention Program to meet the Red Flag
Rule standards. Templates are also provided for job descriptions
for those charged with implementing the dealer’s program with word
tracks to guide customer-contact personnel when addressing Red Flag
issues with customers.
- An F&I office sign alerting customers to the Red
Flag Rule requirements. The sign deters potential identity
thieves, shows customers you’re committed to their protection, and
gives F&I managers a visual prop to explain to customers why
they’re being asked additional questions.
- The sturdy Red Flag Rule F&I DeskCheck, an
easy-to-use aid for screening customer-provided information for
potential indicators of identity theft (red flags), including an SSN
- A copy of the Red Flag Rule as established by the FTC
with current quotable statistics and facts about identity theft and
instructions for addressing credit alert and credit lock situations.
Specific Results –
While the Rule is quite specific about what the end result must be, it
offers a fair measure of latitude in determining the applicable Red
Flags and the systems implemented to apply them to actual situations
with regard to detecting, deterring, and responding to identity theft.
Qualified Legal Review
Every effort has been made to ensure that The F&I Manager’s Guide
to the Red Flag Rule speaks to both the spirit and letter of the FTC’s
interpretation of the governing legislation. Nevertheless, once
this material has been modified to meet the unique needs of your store,
it must be reviewed by competent legal counsel (for whom the dealership
is a bona fide, fee-paying client) before the board approves the
program and it is implemented. The attorney should issue a letter to
the board stating that the program as tendered for review (in his or
her opinion) satisfies the requisites of the Rule.
This applies to the material generated by EVERY program provider or
outside service vendor, including the Red Flag aids drafted by
attorneys – the board should not approve the modified finished product
unless it has been reviewed and affirmed by legal counsel acting at the
behest of the board.
The FTC or other regulatory agency, the plaintiff’s bar, and the media
will want to know exactly where to aim the blame, whether justified or
not, for any identity theft infraction or program-sparked
challenge. As such, those responsible for overseeing the overall
operations (the board of directors or other managerial entity acting in
its stead) should have the final word about whether the plan is
The F&I Manager’s Guide to the Red
plus shipping and handling and applicable taxes
AFIP Industry Members & AIGA Members should contact
AFIP for wholesale pricing and dealer-support information.
Red Flag support is an excellent opportunity to provide
vital additional services to your dealer clients.
DON’T GET CAUGHT
SHORT – ORDER NOW!
Go to www.afip.com/redflag
or call 817.428.2434.