Pub 10 2020 Issue 3

17 inspect the vehicle remotely or send an employee out to appraise the trade-in before you f inalize the terms of the deal, if possible. If you cannot appraise the trade-in before delivering the new vehicle to the customer and the trade-in does not live up to the customer’s description, requiring you to adjust the trade allowance, pause the deal and renegotiate remotely, not on the spot. • Sign as many of the sales documents as possible online. If time permits, arrange to have signed copies of documents that require a “wet ink” signature mailed or shipped to your dealership before you deliver the customer’s vehicle. Documents that require a “wet ink” signature include the motor vehicle title application, the certificate of title assignment area, the power of attorney, odometer statement, and sales tax return. • Deliver RISC in advance (or be prepared to give the customer time to read it before signing) to ensure compliance with Truth in Lending Act disclosures. • Consider having the customer sign an acknowledgement that the dealership did not solicit or negotiate the sale at the customer’s home and that delivery was made as an accommodation to the customer. • Consider requiring customers to come to the dealership for test drives. Bringing a vehicle to the customer’s home for a test drive could be seen as initiating the negotiation process and raise three-day cooling off concerns. • When you deliver the customer’s new vehicle, make sure to follow IADA’s OperationRecommendations for Dealerships (available at www. illinoisdealers.com) or other best practices for sanitizing the vehicle (and the keys) before you hand it over to the customer, and practice safe social distancing, including the use of masks, when interacting with the customer. A word about security is in order. You will want to be thorough with your identity theft Red Flags compliance to be certain that your customer is who he or she claims to be, especially if the customer requests delivery at a location other than the home address listed on the customer’s proof of identity. Consider asking some out of wallet questions to verify identity. Also, if you are transmitting a customer’s private, personal information electronically (credit application, copy of driver’s license, any document with the customer’s social security number or other personal information, etc.), make sure that you are using a secure and encrypted method of transmitting that information. What is and isn’t a secure method of electronic transmission is beyond the scope of this article, but your DMS or other vendor should be able to provide secure, encrypted means of transmission, whereas texting images to your salesperson’s personal cell phone is risky at best. Conferring with your IT provider is highly recommended. Even though technology and state regulators are not fully immersed in the digital age, by using a bit of caution, re- mote sales are a way to fill the needs of your customers.  Results that transform wipfli.com/dealerships Secure your today and innovate for your tomorrow by turning your dealership challenges into opportunities. Contact us today for services in: ■ Audit and accounting ■ Tax ■ Strategic planning ■ Operational assessments ■ Talent management ■ Changemanagement ■ Business transition ■ Cybersecurity