Assistance please. Our indirect auto department will run a credit bureau on each deal they look at from the auto dealer but never speak to the customer during the application process. For fraud and active duty alerts where the consumer asks to be contacted before the transaction is completed, it is sufficient that the dealer make that contact? We have put the dealers on notice that they are responsible for any and all compliance issues and review them on an ongoing basis.

We sent out a letter to all our dealers advising them of the changes, also sent out a modified version of the fraud alert form we are having our lenders complete. We told them in the case of an alert they had to fill this out and forward/bring with their paperwork when they requested funding on their deal. So far not much screaming.

We are taking the opposite approach. We pull credit reports and underwrite applications received from dealers. If the credit report contains a fraud or active duty alert, the bank will use internal procedures to verify the identity of the borrower before proceeding.

What internal procedures would you use? For obvious reasons we really don't want to contact the customer during the application process but how are you handling the issue of the consumer requesting a phone call, etc?

Would you be willing to share the fraud alert form you are using?