At a glance
- Who it's for
- Dealers that arrange financing or hold their own contracts.
- When
- At or before signing the financed contract
- Which rule
- 16 CFR Part 313 for most dealers; 12 CFR Part 1016 for dealers that keep their own paper
- Model form
- Optional, but it counts as meeting the content rules
On this page
Who needs a privacy notice
The FTC's Privacy Rule (16 CFR Part 313) covers dealers predominantly engaged in selling, leasing and servicing vehicles. Dealers that extend credit themselves and don't routinely assign the contracts, which describes most buy-here-pay-here lots, fall under the CFPB's Regulation P (12 CFR Part 1016) instead. The rules are nearly the same.
Per the FTC's dealer FAQ, cash buyers and buyers who bring their own outside financing don't get a notice from the dealer.
When to give it
- Initial notice: no later than when the buyer signs the financed contract, even if you assign it right away (16 CFR 313.4).
- Yearly notice: only while you keep a customer relationship, and not at all if you share only under the rule's exceptions and haven't changed your policies (313.5(e)). When you only broker the loan, the buyer becomes a former customer once the loan is made and you send no more statements (313.5(b)(2)(ii)).
Sharing and the opt-out
Before you share nonpublic personal information with an unaffiliated company outside the exceptions, the buyer must get the notice, an opt-out notice and a reasonable chance to opt out (313.10). The exceptions include service providers and joint marketing (313.13), processing and servicing the deal (313.14), and legal uses (313.15).
The FTC's dealer FAQ also says selling contracts on the secondary market, reporting for manufacturer recalls and processing rebates don't need an opt-out. If you sell or share buyer lists for marketing, they do.
The federal model form
Appendix A to Part 313 is a model privacy form. Using it "constitutes compliance with the notice content requirements," but it "is not required." This generator follows the model form so the layout matches what lenders and examiners expect.
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.
Some states have their own privacy laws with size thresholds. This page covers the federal notice only; the app checks whether a state law applies.
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.