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Nuances in Verifying Identification

Dealers must stay ahead of thieves' evolving game.

by Gil Van Over
April 14, 2023
2 min to read


 

Identity thieves continue to get better, and dealers must ramp up their games to avoid selling a vehicle to an identity thief.

We are a metric-driven industry. Metrics are used to allocate vehicles, to compensate variable managers, and more.

Here are a few soft metrics to gauge compliance with the FTC Red Flags Rules.

Identity theft continues to be one of the fastest growing crimes in the United States.

It is also a constant on lists of consumer complaints.

Dealerships are required to comply with FTC rules designed to protect consumer data from identity thieves and to vet transactions to avoid selling a vehicle to an identity thief, including the Safeguards Rule, Privacy Rule, Red Flags Rule, and Disposal Rule.

The FTC has shot some steroids into the Safeguards Rule. Dealers who do not change their existing Safeguards program will be noncompliant this summer.

The identity thieves continue to evolve and stay ahead of victims and dealerships.

I review over 100 transactions in a normal work week. In those reviews I’ve seen some nuances in acceptable identity confirmation as required in dealerships’ Identity Theft Prevention Program:

  •  Expired ITIN - some finance sources will accept an ITIN for those consumers who do not have a Social Security Number. It is typical to see a Social Security discrepancy flagged in the dealer’s Red Flag rule. I recently saw an ITIN letter that had an expiration date of last year. Be sure to check ITIN letters for any expiration date.

  • OFAC on full name - dealers check OFAC as a matter of course. Many of the OFAC search engines use exact searches, not fuzzy ones. When vetting OFAC, ensure the name is spelled correctly and the full last name is used if there are two names.

  • Matricula, State ID, and Passport - first, these are not driver’s licenses and if used as proof of identification, a dealer should retain documentation of the individual who drove the vehicle off of the lot.

Many finance sources will not accept a Matricula card for identity. Dealerships should follow suit and obtain a U.S.- or state-issued identification or the consumer’s passport.

These thieves continue to get better, and dealers must ramp up their games to avoid selling a vehicle to an identity thief.

Good Luck, Good Selling and Good Health.

Topics:Compliance
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