At a glance
- Breach notice to residents
- 45 days at most
- State regulator notice
- Attorney General (or Department of Financial Regulation for entities it regulates)
- State consumer privacy law
- Vermont Data Privacy and Online Surveillance Act (from January 1, 2028)
- Dealer bond
- $35,000
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.
Vermont's data breach notice law
Vermont's breach notice law is 9 V.S.A. § 2435. If personal information of Vermont residents is breached, it says to notify them in the most expedient time possible and without unreasonable delay, but not later than 45 days after the discovery or notification.
Who else to tell: the Attorney General (or Department of Financial Regulation for entities it regulates). Any breach; preliminary notice within 14 business days of discovery or when consumers are notified, whichever is sooner, plus a copy of the consumer notice when sent.
The law has a clause for businesses that follow the breach rules of their own federal regulator (9 V.S.A. § 2435). 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: "Notice of the security breach shall be made in the most expedient time possible and without unreasonable delay, but not later than 45 days after the discovery or notification"
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.
Vermont's consumer privacy law
Yes. The Vermont Data Privacy and Online Surveillance Act (9 V.S.A. §§ 2415a-2415k) takes effect on January 1, 2028.
Who it covers: Persons conducting business in Vermont or targeting Vermont residents that in the preceding calendar year controlled or processed personal data of 35,000+ consumers (excluding payment-only data), or sensitive data of 3,000+ consumers, or offered for sale the personal data of 3,000+ consumers.
The law exempts only data covered by the Gramm-Leach-Bliley Act, not the business. Credit application data is out of scope, but website, marketing, service and cash-buyer data stay in scope if your store meets the thresholds. (9 V.S.A. § 2415c(a)(13); banks and credit unions exempt as entities under § 2415c(a))
The law reads: "controlled or processed the personal data of not fewer than 35,000 consumers, excluding personal data controlled or processed solely for the purpose of completing a payment transaction"
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.
Vermont dealer license and bond
A Vermont retail dealer license calls for a $35,000 surety bond; other amounts apply to some license types or sales volumes. Everything about the Vermont dealer license: who needs one, the lot rules and the application.
Vermont 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 Vermont's breach deadline in your incident plan
45 days for residents, plus the Attorney General (or Department of Financial Regulation for entities it regulates), 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.
Vermont 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.