Compliance


 

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Compliance

PassTime, an industry leader in GPS tracking and Automated Technology Solutions, created  began marketing the first industry Payment Assurant or also known as code-based product, with no GPS, in 1997.  At that time, 70-80% of the market was held by two payment assurance device companies, PassTime and On-Time.  PassTime began working on the industries first Payment Assurance consumer disclosures, in late 1998.

PassTime, an industry leader in device compliance and device disclosure, has teamed with Hudson Cook, one of the nation’s most highly regarded law practices in the area of consumer financial services law, to create the first available training in payment assurance and GPS device compliance.

PassTime, along with the members of Telematics Solutions Providers Association (TSPA), formally called Payment Assurance Technology Association, has worked diligently to educate national and local government regulators, consumer advocates, dealers, finance companies and consumers on the functionality and consumer benefits of GPS and Payment Assurance devices.

PassTime has a full time compliance officer and CFPB Service Provider documentation.  In the April 2013 CFPB bulletin reiterated the Bureau’s expectation that supervised financial institutions have an effective process for managing the risks of service provider relationships.

PassTime’s strives to ensure corporate wide compliance with new and emerging State, Federal Laws and Regulations.  IT compliance is also an integral part of PassTime’s implementation of best computing and management practices.

 

Payment Reminder/GPS Device Best Practices

  • Do have written policies and procedures for the use of the devices, including (but not limited to) the bullet points listed below.
  • Do fully disclose to the customer that the device is on the vehicle as a condition of financing, how the device works, and optional emergency procedures.
  • Industry best practices require that finance companies/dealers/device owners give written disclosure to the End User Consumer of a SID/GPS device being installed on the vehicle and used as a condition of the extension of credit under the RISC.
  • Written disclosures are supplied by the device provider and should include language outlining the fact that the device is installed on the vehicle, how it operates and will be used, and both the End User Consumer’s and finance company’s/dealer’s/device owner’s respective obligations related to the device. End User must sign the disclosure.
  • Don’t pass the cost of the devices, airtime or installation along to the consumer whose cars are to be equipped with the GPS or Payment Reminder devices associated to the RISC.
  • Don’t discriminate in requiring the devices in any way, as this may violate federal or state anti-discrimination laws.
  • Do track complaints and complaint resolution related to the devices.
  • Do have the personnel who will install the devices properly trained, or use properly trained third-party installers.
  • If possible, give warning prior to disablement (mandatory in California).
  • Where a debtor makes appropriate payment after vehicle disablement, re-enable the vehicle as soon as possible.
  • Do make our insurance policies aware of the use of devices on vehicles.
  • Do not use GPS for any improper purpose.