At a glance
- Breach notice to residents
- Without unreasonable delay
- State regulator notice
- Office of the Attorney General
- State consumer privacy law
- Virginia Consumer Data 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.
Virginia's data breach notice law
Virginia's breach notice law is Va. Code Ann. § 18.2-186.6. If personal information of Virginia residents is breached, it says to notify them without unreasonable delay (reasonable delay allowed to determine the scope of the breach and restore system integrity, or at law enforcement request).
Who else to tell: the Office of the Attorney General. Any reportable breach, without unreasonable delay (same time as residents); if more than 1,000 persons are notified at one time, also the AG and nationwide consumer reporting agencies about timing, distribution and content of the notice.
The law has a clause for businesses that follow the breach rules of their own federal regulator (Va. Code Ann. § 18.2-186.6(G)). 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: "shall disclose any breach of the security of the system following discovery or notification of the breach of the security of the system to the Office of the Attorney General and any affected resident of the Commonwealth 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.
Virginia's consumer privacy law
Yes. The Virginia Consumer Data Protection Act (Va. Code Ann. § 59.1-575 et seq.) has applied since January 1, 2023.
Who it covers: Persons that conduct business in Virginia or target Virginia residents and, during a calendar year, control or process personal data of at least 100,000 consumers, or control or process personal data of at least 25,000 consumers and derive over 50% of gross revenue from the sale of personal data.
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. (Va. Code Ann. § 59.1-576)
The law reads: "(i) during a calendar year, control or process personal data of at least 100,000 consumers or (ii) control or process personal data of at least 25,000 consumers and derive over 50 percent of gross revenue from the sale of personal data."
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.
Virginia dealer license and bond
A Virginia retail dealer license calls for a $50,000 surety bond; other amounts apply to some license types or sales volumes. Everything about the Virginia dealer license: who needs one, the lot rules and the application.
Virginia 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 Virginia's breach deadline in your incident plan
Notice to residents as the law sets out, plus the Office of the Attorney General, 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.
Virginia 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.