RV dealers have some new consumer credit-related Federal Trade Commission (FTC) obligations starting in January, plus new tax elections, the Recreation Vehicle Dealers Association (RVDA) stated in its current issue of RV Executive Today Online.
After five delays over the past three years, the Red Flags rule is finally slated for enforcement. Although a last-minute sixth delay is possible, dealers shouldn’t count on one, because many industry professionals anticipate a broad FTC compliance sweep once the rule is fully enforced. RVDA has sent compliance information and links to free and fee-based compliance templates to all members.
The Risk Based Pricing Rule, which also goes into effect in January, takes another step forward in educating consumers about the effects of their credit scores on their credit rates. It requires that consumers be informed when something in their credit file causes them to receive a less favorable credit rate than the rate offered to a dealer’s best customers.
The Risk Based Pricing Notice (RBPN) that dealers will have to distribute is based on very complex rules, but the FTC allows dealers a safe harbor that simplifies compliance and makes it merely annoying. To help dealers avoid having to calculate complex formulas with each customer, the FTC allows dealers to provide an “exception notice” to every credit customer before the contract is signed.
Also, frustrated by the lack of uniformity in privacy notices that were being given to consumers, the FTC has created a new model form that, if used exactly as directed, satisfies dealers’ compliance obligations.
For more details on these issues and several other new compliance issues, read “Ringing in the New Regulations” in the January issue of RV Executive Today.