When a credit application is sent through DriveCentric, the customer can complete and submit the application online. However, as we all know, we must obtain the customer’s “express authorization” before running their credit.
With RouteOne and many other CRMs, the customer is presented with a final authorization screen before submitting the application. This disclosure confirms that:
The customer gives permission to run their credit
The information provided is accurate and truthful
They are the individual completing the application
The customer must actively agree to these terms before the application can be submitted. This process provides documented “express consent” from the customer.
Currently, this authorization step appears to be missing in DC. As a result, many dealerships may be pulling credit applications without documented express consent from the customer, which could create compliance concerns.
"Federal law under the Federal Trade Commission Fair Credit Reporting Act (FCRA) requires a “permissible purpose” to pull a consumer’s credit report. In auto financing, that permissible purpose is generally established when the consumer applies for credit and/or provides written authorization."