Cyber Security - Is your Auto Dealership Prepared?

Two years after General Motors hired its first Chief Product Cyber Security Officer the auto industry released its first ever cybersecurity best practices guide. With the cybersecurity threat expanding rapidly we have to ask ourselves…what’s next?

Cybersecurity is a well-known threat, especially to the auto industry. It is not only the auto dealer’s internal operational and financial systems, but the cars themselves, that pose a cybersecurity threat. As reported by Forbes, it is expected that by the Mid-2020s all new vehicles will have data connections. We have seen significant communication advances between manufacturers and cars. Current products exist where auto dealerships can download and monitor activity of their customers’ vehicles on a real time basis. Faced with statistics like this, now is a more critical time than ever, to take steps to get ahead of hackers.

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Motivation and Passion for the Profession

I was asked recently to give an informal presentation to our team about the different aspects of the day to day work that I do and why I do it. This was a great opportunity for me to stop and reflect on the purpose of my career, the purpose of our firm, and the impact we have on peoples’ lives.

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The CFPB - Where do they stand now and what does it mean to you?

The Consumer Financial Protection Bureau’s (CFPB) indirect crusade against dealers has been ongoing for several years now. For those who are not familiar with the auto dealership model, dealer participation is a method whereby a dealer arranges a wholesale rate of financing for a customer and then marks it up to a rate equal to that which the customer could find in the retail marketplace. As the NADA describes in their article, “The Fallacy of Flats” , the CFPB has essentially claimed that this provides the dealer with a level of pricing discretion that creates a “significant risk” that certain groups of consumers will pay a higher interest rate (due to more dealer participant) than other groups of similarly situated consumers in violation of the federal Equal Credit Opportunity Act. Although auto lending policies strictly prohibit gathering information on ethnicity, the CFPB has claimed evidence of this violation as a result of its efforts to categorize borrowers into ethnic groups based on the borrower’s name and the zip code in which they reside. The accuracy of the CFPB’s categorization has come under question on many fronts but it has not deterred them from their crusade.

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