At a glance
- Breach notice to residents
- Without unreasonable delay
- State regulator notice
- Office of Consumer Protection (Dept. of Commerce and Consumer Affairs)
- State consumer privacy law
- None
- Dealer bond
- $50,000
On this page
Federal rules every dealer follows
These apply in every state. Each links to a free tool or guide.
- FTC Safeguards Rule (16 CFR Part 314): a written security plan, a Qualified Individual, a risk assessment, MFA, encryption and the FTC breach notice. Safeguards checklist.
- Red Flags Rule (16 CFR 681): a written identity theft program; most dealers who arrange financing treat themselves as covered. Red Flags program.
- Privacy notice (Gramm-Leach-Bliley Act): give it to buyers who finance or lease. GLBA privacy notice.
- OFAC: never sell to someone on the Treasury's sanctions lists; keep records 10 years. Free OFAC search.
- Form 8300: report cash over $10,000 within 15 days. Form 8300 worksheet.
- Credit notices: adverse action within 30 days, and risk-based pricing notices. Adverse action notice.
- Used Car Rule: the Buyers Guide on every used car for sale. Buyers Guide.
- Advertised prices: include doc fees and other required fees, per the FTC's September 2026 FAQs. Ad and price check.
Hawaii's data breach notice law
Hawaii's breach notice law is Haw. Rev. Stat. § 487N-2. If personal information of Hawaii residents is breached, it says to notify them without unreasonable delay, consistent with law-enforcement needs and measures needed to identify contacts, determine the scope of the breach and restore data system security.
Who else to tell: the Office of Consumer Protection (Dept. of Commerce and Consumer Affairs). If more than 1,000 persons are notified at one time; in writing, without unreasonable delay (nationwide consumer reporting agencies must also be told), covering the timing, distribution and content of the notice.
The law has a clause for businesses that follow the breach rules of their own federal regulator (Haw. Rev. Stat. § 487N-2(g) (financial institutions subject to the federal Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice (GLBA-based), or 12 C.F.R. Part 748 for credit unions, are deemed in compliance; also HIPAA-covered health plans/providers)). Some clauses like this cover only banks and credit unions, so don't count on it: plan to meet the state deadline as well as the FTC's.
The law reads: "The disclosure notification shall be made without unreasonable delay,"
This is on top of the federal rule. Under the FTC Safeguards Rule, a dealer must tell the FTC within 30 days of discovering a breach of unencrypted information about 500 or more consumers. How the FTC notice works.
Does Hawaii have a consumer privacy law?
Hawaii has no comprehensive consumer privacy law like California's as of October 31, 2026. The federal privacy rules still apply: a dealer that arranges financing or leases gives each of those buyers a privacy notice under the Gramm-Leach-Bliley Act. Make a free GLBA privacy notice.
Hawaii dealer license and bond
A Hawaii retail dealer license calls for a $50,000 surety bond (line of credit (or a bond from $25,000 if the Board accepts one instead)). Everything about the Hawaii dealer license: who needs one, the lot rules and the application.
Hawaii dealer compliance checklist
Write and sign your security plan
Name your Qualified Individual, do the risk assessment and turn on MFA for every system with customer data.
Adopt a Red Flags program
Check the buyer's ID on every deal and log what you checked.
Give the privacy notice
To every buyer who finances or leases, at or before signing.
Check every buyer against the OFAC lists
Keep the dated result in the deal jacket for 10 years.
Track cash
Add up related cash payments and file Form 8300 when they pass $10,000.
Train your staff on security
The Safeguards Rule asks for security awareness training for everyone who handles customer data. Keep a record of who finished it.
Put Hawaii's breach deadline in your incident plan
Notice to residents as the law sets out, plus the Office of Consumer Protection (Dept. of Commerce and Consumer Affairs), and the FTC within 30 days at 500 or more consumers.
Check your ads
Advertised prices include doc fees and every fee all buyers pay.
Rules checked and limits
Rules checked October 31, 2026. We read every rule on this page in the eCFR or on the agency's own site, and each is linked in the sources below. We re-check them every quarter.
Hawaii laws checked October 31, 2026 on the official sources linked below.
Templates and tools, not legal advice. CarShots is software, not a law firm. For a question about your own dealership, ask your attorney or your state dealer association.