His book offers some dos and don'ts for dealerships accepting credit applications online:
1. Adopt clear, written policies for taking online credit applications.
2. Set the Web site to provide click-through authorization before the customer can proceed with online credit application.
3. Use encryption technology to make sure transmission of the credit application is secure.
4. Never let dealership employees ask customers to submit credit applications or other personal information over unsecure media such as e-mail.
5. Never share credit information with customers until they arrive at the dealership and present proof of their identity.
8. Mail an adverse action notice to consumers if the dealership can't obtain financing for them.
9. Mail customers a credit score disclosure within two days after pulling the credit report to comply with the federal Risk-Based Pricing Rule. Be sure to mail the disclosure to the current address shown on the credit report, rather than the unverified address on the credit application.
10. Don't mail the credit score disclosure if customers clearly withdraw their credit application.