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New York dealer compliance

New York dealer compliance checklist

What a New York car dealer needs to stay compliant: the federal rules every dealer follows, New York's data breach notice law, its consumer privacy law status and the dealer bond, with the official source for each.

At a glance

Breach notice to residents
30 days at most
State regulator notice
State Attorney General, Department of State, and Division of State Police; also Department of Financial Services if a covered entity under 23 NYCRR 500.1
State consumer privacy law
None
Dealer bond
$20,000
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.

New York's data breach notice law

New York's breach notice law is N.Y. Gen. Bus. Law § 899-aa. If personal information of New York residents is breached, it says to notify them in the most expedient time possible and without unreasonable delay, and within 30 days after the breach has been discovered (except for legitimate law enforcement needs).

Who else to tell: the State Attorney General, Department of State, and Division of State Police; also Department of Financial Services if a covered entity under 23 NYCRR 500.1. Whenever any New York residents are to be notified; without delaying notice to residents (DFS notice per 23 NYCRR 500.17). Consumer reporting agencies if more than 5,000 New York residents are notified at one time.

The law has a clause for businesses that follow the breach rules of their own federal regulator (N.Y. Gen. Bus. Law § 899-aa(2)(b)). 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 shall be made in the most expedient time possible and without unreasonable delay, provided that such notification shall be made within thirty days after the breach has been discovered"

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 New York have a consumer privacy law?

New York 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.

New York dealer license and bond

A New York retail dealer license calls for a $20,000 surety bond; other amounts apply to some license types or sales volumes. Everything about the New York dealer license: who needs one, the lot rules and the application.

New York dealer compliance checklist

  1. Write and sign your security plan

    Name your Qualified Individual, do the risk assessment and turn on MFA for every system with customer data.

  2. Adopt a Red Flags program

    Check the buyer's ID on every deal and log what you checked.

  3. Give the privacy notice

    To every buyer who finances or leases, at or before signing.

  4. Check every buyer against the OFAC lists

    Keep the dated result in the deal jacket for 10 years.

  5. Track cash

    Add up related cash payments and file Form 8300 when they pass $10,000.

  6. 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.

  7. Put New York's breach deadline in your incident plan

    30 days for residents, plus the State Attorney General, Department of State, and Division of State Police; also Department of Financial Services if a covered entity under 23 NYCRR 500.1, and the FTC within 30 days at 500 or more consumers.

  8. 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.

New York 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.

Common questions

How fast must a New York car dealer report a data breach?

New York's law (N.Y. Gen. Bus. Law § 899-aa) says to notify affected residents in the most expedient time possible and without unreasonable delay, and within 30 days after the breach has been discovered (except for legitimate law enforcement needs). Also tell the State Attorney General, Department of State, and Division of State Police; also Department of Financial Services if a covered entity under 23 NYCRR 500.1. Whenever any New York residents are to be notified; without delaying notice to residents (DFS notice per 23 NYCRR 500.17). Consumer reporting agencies if more than 5,000 New York residents are notified at one time. Separately, the FTC Safeguards Rule asks for an FTC notice within 30 days when 500 or more consumers are affected.

Does New York have a privacy law that applies to car dealers?

New York has no comprehensive consumer privacy law as of October 31, 2026. Dealers that arrange financing or leases still give the federal GLBA privacy notice.

What federal compliance rules apply to New York car dealers?

The FTC Safeguards Rule, the Red Flags Rule, the GLBA privacy notice, OFAC sanctions checks, Form 8300 for cash over $10,000, adverse action and risk-based pricing notices, the Used Car Rule's Buyers Guide, and the FTC's pricing rules for ads.

How much is the New York dealer bond?

$20,000 for a retail dealer license, with other amounts for some license types or sales volumes. See the New York dealer license guide.

Get your New York compliance program in ten minutes

Answer about ten minutes of questions. Get your score, your gap list and a watermarked draft of your security plan, free with no card. Essentials is $99 per store a month when you're ready.