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Tennessee dealer compliance

Tennessee dealer compliance checklist

What a Tennessee car dealer needs to stay compliant: the federal rules every dealer follows, Tennessee'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
45 days at most
State regulator notice
Not required
State consumer privacy law
Tennessee Information Protection Act
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.

Tennessee's data breach notice law

Tennessee's breach notice law is Tenn. Code Ann. § 47-18-2107. If personal information of Tennessee residents is breached, it says to notify them no later than 45 days from the discovery or notification of the breach, unless a longer period is required for legitimate law enforcement needs.

The law has a clause for businesses that follow the breach rules of their own federal regulator (Tenn. Code Ann. § 47-18-2107(i)). 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 must be made no later than forty-five (45) days from the discovery or notification of the breach of system security, unless a longer period of time is required due to the legitimate needs of law enforcement"

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.

Tennessee's consumer privacy law

Yes. The Tennessee Information Protection Act (Tenn. Code Ann. § 47-18-3201 et seq.) has applied since July 1, 2025.

Who it covers: Persons that conduct business in Tennessee producing products or services that target residents, that exceed $25,000,000 in revenue, and that either control or process personal information of at least 175,000 consumers in a calendar year, or of at least 25,000 consumers while deriving more than 50% of gross revenue from the sale of personal information.

The law exempts both financial institutions subject to the Gramm-Leach-Bliley Act and the data that act covers. A dealer that arranges financing or leases is generally treated as one, so ask your attorney whether that covers your store. (Tenn. Code Ann. § 47-18-3210(a))

The law reads: "Exceed twenty-five million dollars ($25,000,000) in revenue"

Whether your store is covered depends on your own numbers, so check them each year, and keep giving financing buyers the federal privacy notice. Make a free GLBA privacy notice.

Tennessee dealer license and bond

A Tennessee retail dealer license calls for a $50,000 surety bond. Everything about the Tennessee dealer license: who needs one, the lot rules and the application.

Tennessee 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 Tennessee's breach deadline in your incident plan

    45 days for residents, 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.

Tennessee 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 Tennessee car dealer report a data breach?

Tennessee's law (Tenn. Code Ann. § 47-18-2107) says to notify affected residents no later than 45 days from the discovery or notification of the breach, unless a longer period is required for legitimate law enforcement needs. Separately, the FTC Safeguards Rule asks for an FTC notice within 30 days when 500 or more consumers are affected.

Does Tennessee have a privacy law that applies to car dealers?

Tennessee has the Tennessee Information Protection Act. It covers: persons that conduct business in Tennessee producing products or services that target residents, that exceed $25,000,000 in revenue, and that either control or process personal information of at least 175,000 consumers in a calendar year, or of at least 25,000 consumers while deriving more than 50% of gross revenue from the sale of personal information. Whether a store is covered depends on its own numbers. The federal GLBA privacy notice applies either way.

What federal compliance rules apply to Tennessee 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 Tennessee dealer bond?

$50,000 for a retail dealer license. See the Tennessee dealer license guide.

Get your Tennessee 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.