A Dealer's Guide to the Red Flags Rule

Red Flags Service

The Red Flags Service includes A Dealer's Guide to the Red Flags Rule, by Michael A. Benoit, as well as a complete set of Downloadable Templates and Documents to help you manage your Red Flags Rule compliance.

A Dealer's Guide to the Red Flags Rule is a handy reference tool that provides busy dealers with a step-by-step roadmap to designing and implementing an Identity Theft Prevention Program as required by the Federal Trade Commission's new Red Flags Rule, in advance of the January 1, 2011 mandatory compliance date. The topics address how to design and implement reasonable policies and procedures to:

  • Identify Red Flags in the dealership
  • Detect and evaluate Red Flags at the customer transaction level
  • Respond appropriately to the Red Flags detected
  • Periodically update the Identity Theft Prevention Program as necessary
  • and more ...

A Dealer's Guide to the Red Flags Rule contains helpful suggestions for managing the Identity Theft Prevention Program in the dealership, as well as a sample Identity Theft Prevention Program dealers may use as the basis for their own specific Programs. The information is presented in an easy to read format, with as little "legalese" and as much useful and practical information as possible. The goal is to give dealers a solid, basic working knowledge of the Red Flags Rule.

Downloadable Sample Templates

  • Sample Identity Theft Prevention Program
  • Risk Assessment Questionnaire
  • Customer ID Verification Checklist
  • ID Theft Incident Reporting
  • Annual Board of Director Reporting

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Michael Benoit

About the Author

Michael Benoit is a partner in the Washington, D.C., office of Hudson Cook, LLP. He advises banks, sales finance companies, auto leasing companies, auto dealers, and other creditors and technology providers on a wide range of consumer financial services law and F&I compliance.

Michael is a frequent author on a variety of F&I and consumer financial services law topics. His monthly articles appear in Auto Finance News, F&I Management and Technology magazine, and Powersports F&I and he has contributed to the ABA's Business Law Journal, Mortgage Banker Magazine, and Spot Delivery. He is the editor and an author of CounselorLibrary.com's F&I Legal Deskbook (2d Ed.), the leading dealer-oriented reference on F&I compliance matters.

Michael frequently speaks before a variety of industry and trade groups, and has been engaged by the National Automobile Dealers Association, the National Vehicle Leasing Association, the Mortgage Bankers Association, the Conference on Consumer Finance Law, the American Bar Association, and various dealer groups and finance companies.