Are Your Device Practices Ready for a Closer Look?

Five practical steps that can protect your customers and your dealership.

If your dealership uses GPS, or starterinterrupt devices, here is a simple question: If a customer or regulator asked why a device was used, could you quickly show exactly what happened?

That question matters because the regulatory landscape keeps changing. Federal priorities may shift, but state regulators and attorneys general are still paying close attention to the auto industry. They are looking at the full customer experience, including advertising, financing, add-on products, servicing, data use, and repossession.

THE GOOD NEWS IS THAT A STRONG DEVICE PROGRAM DOES NOT HAVE TO BE COMPLICATED. IT STARTS WITH A FEW CLEAR REPEATABLE PRACTICES.

1. Write down the rules.
Do not leave device decisions to habit or guesswork. Your policy should explain when a device is required, who is responsible for each step and who can approve an action. Choose someone to own the program, limit access to authorized employees, and give staff a clear path for questions or unusual situations. Note all one-off situations or exceptions. Review those exceptions and review them regularly, to determine if what once was an exception has turned into standard policy. Written rules help sales, collections, servicing, and installation teams work from the same play book.

2. Explain it clearly to the customer.
A signature alone does not mean the customer understands. Before the sale is complete, explain why the device is installed, how GPS and starter-interrupt features work, when the device could be used, what the customer should do after a missed payment, and any override trainings if applicable. Be clear about fees, support, overrides and removal. Use plain language, give the customer a copy of the disclosure and keep the signed version in your records.

3. Build safeguards into every device action.
Compliance does not stop after installation. Use trained installers and keep records of installations and repairs. Before activating a starter-interrupt feature, send a reminder, provide advance warning and doublecheck the account status, grace period and eligibility. Once the appropriate payment is made, restore the vehicle promptly. When the contract ends, remove the device or shut off the dealership's access.

4. Protect the data and keep the proof.
Only trained, authorized employees should have access to location and device information. Use the data only for approved purposes, store it securely and follow a written retention schedule. Keep enough information to show the full story, including notices, approvals, activations, payments, reactivations, complaints, and resolutions. What are your device providers doing to protect that data? Ask for a safeguards policy. You have a responsibility to monitor and manage your providers. Doing the right thing matters, but so does having the documentation to prove it.

5. Check the program regularly.
Rules change, staff members change, and small gaps can grow into bigger problems. Review federal, state, and local developments, audit account files and device activity, and look for patterns in downtime, disputes and complaints. Ask employees, customers, and installers what is working and what is causing confusion.

Their feedback can point to fixes that a policy review might miss.

Advocacy also has a place in this conversation. A proposed law can sound reasonable on paper but create unexpected problems for customers, credit access, or dealership operations. Dealers can help lawmakers understand the real-world impact by building relationships early, sharing short and specific examples, and staying connected through their state association and NIADA. A local dealer's story can often make an issue much easier to understand.

It is not always easy to step away from the dealership, but that is exactly why the MidAtlantic IADA convention is worth the time. You can compare your process with other dealers, talk directly with experts and bring home ideas your team can use right away. Ask this question while you are there: “Could we recreate our device decision, from disclosure to the end of the RISC, with the records we have today?”

The answer may uncover a missing policy, training step, or record before it becomes a customer complaint or regulatory problem. The goal is straightforward: explain it clearly, use the device carefully and keep the records that show you handled it the right way.

Can’t wait to see you all at MidAtlantic IADA Conference October 4-5th.