I work with an indirect lender of auto loans through auto dealers. Would we be required to have an Identity Theft program? We have the Identity Theft requirements stated within dealer agreements that they need to comply. What would we be required to do being an indirect lender? I appreciate your feedback.

We also have a division that purchases indirect paper from dealers, and we require them to establish a program that will identify and mitigate identity theft. In addition we require them to conduct and provide proof of CIP on all applicants. We also as per our contract require them to re-purchase all fraudlent accounts. Hope this helps