others such as internal penetration testing, vulnerability assessments, data encryption, security awareness training, and the performance of written risk assessments. WVADA has and will continue to host webinars for dealers and their staff to assist with complying with this rule. Apparently, the implementation of the Safeguards rule was not enough for the FTC and now they are at it again with a new UDAP rule. This proposed rule includes a prohibition on add-on charges that do not provide value to the customer, new record retention requirements for advertisements, training materials and marketing, and specific disclosure requirements for a vehicle’s “offering price” and optional add-on products. However, the FTC fails to provide sufficient support to justify its sweeping set of proposed duties and restrictions. “NADA is mounting a comprehensive and detailed response to the proposal, which will defend the highly competitive and pro-consumer benefits of the optional, dealer-assisted financing model, and show that, in fact, the FTC’s proposal is likely to harm consumers,” said Mike Alford, President of NADA. The FTC has provided the public 60 days to respond to the proposed rule after it is published in the Federal Register. NADA has requested an extension of time to file and submit an in-depth response to the FTC’s proposal that will further educate the FTC on the array of consumer benefits provided by dealers and explain how the many flaws in the FTC’s proposed rule will threaten those benefits. Again, this article is not meant to scare or cast a gloom over our industry. Rather, I hope this article educates and inspires you to continue to be innovative and offer consumers second to none experiences. We must demonstrate to the OEMs and the FTC the important role that franchise dealers play. It is extremely important for you to be or continue to be involved with WVADA and NADA. Your franchise is under attack on all fronts, franchise dealers must continue to show their value while creating a unified front through our strong Association. WVADA vows to protect your investments and combat future uncertainties, but we must do it together. It is a privilege serving as your President, and as always, do not hesitate to contact me if I can be of any assistance. Sincerely, Jared Your franchise is under attack on all fronts, franchise dealers must continue to show their value while creating a unified front through our strong Association. Continued from page 6 wvcar.com 8 WVADA
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