Permissible purpose is the legal justification the Fair Credit Reporting Act (FCRA) requires before anyone can access a consumer's credit report. Consumer permission is the customer's explicit authorization to check their credit, but permission alone does not automatically satisfy the FCRA's permissible purpose requirement. ...
No, you don't always need a full Social Security number to run a credit check. Whether an SSN is required depends entirely on what kind of credit check you're running. A prequalification or soft pull can often be completed with just a name and address at a minimum, but date of birth and possibly the last four digits of an SSN may also be included. ...
Do prequalification soft pull credit reports have compliance requirements? Yes. This type of soft pull still requires a permissible purpose under the Fair Credit Reporting Act (FCRA), still triggers data-security obligations under the FTC Safeguards Rule, and can, in some situations, still create an adverse action notice requirement if the information is used to decline or price an offer of credit. ...
You've extended a credit offer. The customer is approved. But their interest rate is higher than what you advertised or higher than what someone else walking through the door might receive. Under federal law, you may be required to tell them why....
A Texas dealership flipped on real-time identity checks for the first time on a Tuesday morning. Five days later, its system flagged a doctored driver's license mid-deal, and a detective was walking a suspect out in cuffs before she ever got the keys. ...
Nearly one in three trade-ins walking onto a dealer’s lot right now is underwater. That's according to the latest data from Edmunds, and it's a problem every desk manager in the country is fighting....
Clint Eastwood made the good, the bad, and the ugly famous. In the wild west era of agentic search, it turns out dealer payment data has the same three categories....
Cars are in my blood. My family had dealerships including those that sold European and Japanese imports in the Pacific Northwest, which eventually became Knievel Imports. Yes, that Knievel. Evel is my uncle....
Roughly four out of five car buyers finance or lease. That number has been stable for years. It’s not a trend. It’s a structural feature of how Americans buy cars. ...
I don’t usually fly home from a conference still mentally in the room. But sitting in the airport after the CBT News Auto Leadership Summit on Fair Pricing & Compliance in Washington, D.C., notes scattered, phone full of screenshots, I couldn’t stop thinking about what I’d just heard....