#231 - Safeguard Rule Changes Explained - TIADA Special

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You are listening to the Independent Dealer Podcast Texas Edition, with hosts Luke Godwin and Jeff Watson, a podcast by dealers for dealers.

Hello and welcome to the Independent Dealer Podcast Texas Edition. Luke Today we have two very special guests to talk about one of my favorite and most exciting topics. You know me, I always, always love to chat about compliance.

Everybody loves to chat about compliance. It's like when you go to the convention, the first thing that everybody just runs to is all the compliance sessions because it is so much fun. But unfortunately, Jeff, it is super necessary. And we have two very qualified individuals to talk to us today about this and also a way for us to get compliant because there is definitely a new law out there and we have to adhere to it. So let's get going. Jeff.

Yeah, Earl, Greg, let's start with you, Earl. Introduce yourself to the community real quick. Give us a quick background on what you do and how you're here to help us.

So I'm the director of compliance and Business Development manager for Texas Independent Auto Dealers Association. I've been with us about a year and a half. Before that, I spent time at UGA Law, the West Virginia legislature, Asbury Automotive Group. Nada. Went to law school after 15 years in the car business and kind of just wanted to work on the compliance side of things because it is so exciting.

I figured that after that many years on the working for a car dealer, you would have known exactly how to sue us all and so you would become a plaintiff's attorney on that side. I mean, that's what I would have done. I would have just been rolling in dope.

I thought about it.

Trust me.

Yeah.

You know, everything we do wrong, find all the soft spots. And Greg, introduce yourself to us.

I'm the general counsel and chief compliance officer for Coast To Coast Motors and all of our sister companies, Crossroads, Autumnal, CTC Financial, Auto Net Finance Company. Been here for four years. And my main goal is to protect the company. And so compliance is obviously one of the big arrows in that quarter.

Well, Greg, you're here to kind of to introduce us to how these rules take effect on the dealership side. And you're kind of unique. It's a big company, and I'm sure that there's a lot more compliance that goes on. And luckily, Coast to coast is able to have someone like you in house handling this for them. So thanks for being here. How many people do you have to worry about this compliant aspect for, Greg? I just want to know that up front so we can kind of get.

An idea for the safeguards or for the whole company?

For the whole company. I mean, there's a lot of compliance going on here.

Yeah, 240 employees.

That's a lot of folks to keep compliant. You have a hard job, a whole lot more customers.

So, yeah, a lot to do, that's for sure.

All right, well, Jeff, you ready to jump into this?

Yeah. I mean, when I think compliance, and I don't want to belabor the point, but, yes, it's like there's a few things that make me glaze over faster than the word compliance. Like, you know, my wife asking me if she looks fat or an employee asking for a raise.

Raise.

Like, I will just instantly go. I will check out mentally. But here's the thing that I thought about is we. We should care as dealers because we want other businesses to care about us when we're consumers. Right. I mean, that's kind of what struck me the other day, is like, I don't want to go into a business that isn't compliant, that isn't taking care of my personal information the way they should be. How in the world would I run a business that's any different than that, you know? So that's probably the biggest setup that I have is like, man, this is just. This is what we should be doing.

And this is big time, and this is big time money out there. I mean, you talk about attorneys on the plaintiff sides for not handling your data properly. So this is something we really need to talk about. And, Earl, thank goodness you're here. And you've kind of led us down a good path to get compliant. So can you just give us a quick overview of what the FTC safeguard rules were and now what they are kind of the differences and what dealers need to do.

So the Grammleach Barley act is what kind of promulgates these rules and where they come from. That was passed in 99. Most dealers are probably. Remember in 2001, the privacy rule, where you have to give out privacy notice? I remember I was working at the dealership. It was such a big deal. But the big thing for us was, you know, the government wants to explain sharing practices to the customer with the privacy notice, and then they want you to safeguard sensitive data. The safeguards rule originally took effect in 2003. A lot of people ask, what is the difference between the old rule and the new rule? The biggest difference is now they have more specific guidelines, and they actually tell you you need to have a written assessment. You have to have document on the training. A lot of the stuff though that they asked of dealers in 2003 is currently the same as being asked now. They're just putting it into a more defined scope. And one of the issues has always been, is relative to your size and what you have to do.

Yeah, that's, that's a big part of this law. And I, I've always wanted to be really big and now I'm kind of glad I'm not huge. But you know, so Greg, when we talk about the things that have changed, I mean, how seriously do dealers really need to be worried about this? How seriously are y' all worried about it in your dealership?

I mean, we take it very seriously. I think the FTC made the change for a reason. You see the headlines with hacking and malicious malware being on company computers and data being stolen and you know, at the end of the day, whether it's one customer getting their MPI stolen, you know, and maybe it's someone harassing them or if it's a whole bunch of people in a big hack, you know, it's going to be a very expensive uphill climb to get out of it. So you want to be proactive and take care of your customers private information and the easiest way to do that is to meet the regulations that are currently in place.

Yeah. And Errol, tell me this, I think as me as a small dealer, right, I'm nowhere the size of Greg. So my argument or my justification would be I'm a tiny little fish, you know, I'm, I'm not on the FTC's radar. Right. I mean I don't have to worry about it as like a 10 person operation. Like what are the chances of me getting, you know, picked out and attacked?

Since I've always told dealers, the biggest concern to me is not the ftc, not private action. But hey, you lose information, you end up on channel four and wait and see what traffic, traffic looks like it a lot. That to me is the scariest. From a business perspective it's not really so much, you know, the fines and the enforcement actions, those are scary too. But what scares me is you lose this data. It's very good news worthy story. And if you can't show that you did some precautions, it's going to look really bad for you and really affect your business negatively.

Yeah, I had a, so I had an experience about six months ago where we have an internal server here that we just keep documents on, shared documents and it got ransomware, it got locked down and I had to take the file out to the guy, and he saved some of it. But luckily, I wasn't keeping any personal data on there. That wasn't, you know, a file source with people's names and info. It was just our silly documents and. And things. And it was ransomed, but it could have been. It could have been snagged. So, yeah, my little teeny dealership got attacked. It's crazy.

Well, that brings up something. I was thinking about, Jeff. I was taking this course that Tiada offers. I was thinking, you know, a lot of the. A lot of the data I have is not stored on. On my system. I mean, we. We are using other companies that are a lot bigger than I am, and they kind of house that data, that personal information. Greg and Earl. Greg, you deal with this every day. I know, I know. Y' all use the same software I use. What do we do? I mean, how. I. Let me. Let me back up here. We don't have the data. Another company has the data. So what. What do we need to do when that's the case? Because I don't store customer credit card information or anything like that.

Earl, do you want to take this one? You want me to take it?

Either way. I'm fine either way. What do you prefer?

Well, I can tell you what we do is, you know, right when this rule came down, it was announced last year, started reaching out to vendors just to see what their current practices were, to see if they were going to implement their own two factor authentication, and in the meantime, getting amendments drafted and ready to go for them to sign by December this year. So. Excuse me, amendments to our vendor agreements, just so they are obligated contractually to abide by these safeguard rules, and because at the end of the day, we're going to be liable for breach regardless of where the information was stored.

That's what's interesting, right? I mean, we are responsible for using a vendor that has an issue.

Yeah, Scary stuff, right?

That is kind of scary because they have a lot of data. A lot of data. So that is super scary. Earl.

Let me dig into that, though. Greg, Two Factor authentication. Is that going to be required of all of our vendors? And maybe Earl knows this as well.

Is that.

Is that going to. Something we're going to see commonplace?

Yeah, I think it's. You know, we're trying to figure out whether we're going to roll it out internally or whether our vendors are going to roll it out. You know, currently I'm thinking that it's going to be internally. So we'll have our computers with anyone, anyone that accesses a specific computer that can get to the customer mpi, it's probably going to have to two factor authentication. You know, I can tell you from looking through cyber insurance policy quotes, almost all of them require two factor authentication. And then the few that don't require right now, I'm told, are going to be going by the wayside. So, you know, in the short to medium term, if you want cyber liability protection, you're going to have to have two factor authentication.

And let's, let's bring that down. Let's tell layman's term, let's tell everybody what two factor authentication is. I know what it is. Everybody here probably knows what is, but there's probably people out there that don't know what it is.

Yeah, Earl, take it.

So I think the easiest for most people you can think of is you type in your password, then they text you a code and you have to type in the code afterwards. You need two different things to authenticate. Could be your face, it could be a fingerprint, and then password typically is the second item. So you would.

So what you're saying, Greg, is you're going to implement that on your computers, in your dealerships. If my softwares aren't going to have it up and running, I'm going to take the proactive to say I'm going to do this. Is that what you're saying?

Yeah, I mean that's a. Guys, you know, trying to figure out how we're going to do it. What kind of two factor authentication is going to be? You know, is it going to be those little things you carry around that has a, has a number of, that you changes every seven minutes and that you put it in along with your password? Or is it going to be something like Earl said? I don't know the specifics yet, but.

I definitely think there's a lot of dealers out there with computers that think the screensaver is their security. You know, like, well, when I leave my desk the screen turns off or I have a screensaver that pops up or, you know, I don't have a password, or it's 1, 2, 3, or you know, like. I think a lot of times that doesn't even dawn on us. It's like, wait a minute, you have no password on your computer because you think you have a password into your software systems. But guess what? All your software system passwords are saved on your computer. So yes, anyone that sits in your chair has access to everything.

Let's talk real quick about the deadlines. Earl, there are some strict deadlines on this, and we keep kind of brushing around. When does this really take effect and really affect us 100%?

So the first part of it took effect January 10th of this year. Most of the stuff that took effect was things that we already, the FTC felt you should have already been doing anyways they felt wasn't a big obligation. The second part that takes effect is on December 9 this year that you have the monitoring services. You gotta have two factories. You got to have the written incident response plan. There's several different things that you have to do based on that. Most of those requirements, though, are based on you having 5,000 consumers. So your written assessment, continuous monitoring, annual penetration testing, vulnerability assessments, written incident response plans, all for people who have 5,000 consumers. So most of the smaller dealers is 100% effect at this point. The larger dealers got a little bit of a pass because they have harder requirements that are required of them. They're more costly and time consuming.

What's interesting is that 5,000 consumer yalls, it talks about customers and consumers. And you'll learn this as you take. As you take this test. But a dealer that sells 40 cars a month and finances them, they vary well. May have 5,000 consumers. And so you're not even thinking about someone who has 10,000 accounts, being that it could be someone as little as a thousand accounts or 800 accounts that are hitting that level. So it's something that you have to put in place and try to figure out. We won't go into those calculations right this second, but it's. It's in the. It's in the compliance test. And something you really need to look at. What. What can dealers do right now? Earl, what kind of things should we be putting in place policies and procedures so that we will be ready come December 1st or December 9th.

So one of the easiest things probably is to make sure you designate a.

Single person for your program.

Make sure that you have one single qualified individual that's in charge of your compliance. Much like Coast to coast done. Greg's in charge of that. Having one person in place, I think is your first step on anything because you have somebody who will dedicate time to it. One of the hardest things with compliance in general is setting aside time to do it. Often it's on the back burner. You know, selling a car is more important. It's just not a priority. But you have to make it a priority at some point. Yeah.

And what actions this. Maybe this is a question for Greg. Give us some tips or actionable items that these dealers can start doing right now. Like, like when I get off this call and I'm a three person operation and I'm done listening to this, what should I go run out and kind of implement right away that I've been missing?

Well, I think two of the. Well, really doing anything as soon as possible I think is important, but I think getting the training done and then having written policies and procedures are the two things that you can really do to get started and those policies and procedures can change. But you know, I think you really need to get out there and at least make an attempt at a first draft. Really think about where your customer information can be vulnerable, how it's communicated. You know, for example, when a customer comes in and asks for some information on their account, how do you verify that that customer is who they say they are? Do you know them? Do you ask if you don't know them? Do you ask for id? Do you ask for some kind of verification instead of just saying oh yeah, here's this information and then maybe you get unlucky and it's not the customer, someone else being decevious or devious. Excuse me. Yeah, those are probably the two biggest things, just written policies and procedures and really just put a lot of thought into where the non the NPI stored and then how it's communicated and given out.

Yeah, I think for myself, you know, I think about all my lack of maybe preparation or things. And you know, we talk to dealers so many times about having your policy and procedures manual. Right. All dealers should have an Excel spreadsheet, a Word doc, a Google Doc written on a napkin. Whatever they do to make sure all their policies and procedures are written out. And this is a huge section of that. This should be in the very front. It should be reviewed often. And like Greg said, what is the policy for verifying someone's info on a test drive, on a payment, on a. Someone calls in and wants to give you a credit card for something. You know, these things all need to be written down and then they need to be reviewed regularly. One of the biggest things would be go out to your salesman's desk and see how many credit apps are laying around.

Absolutely.

You know, at 7 o' clock at night before you go home, how many apps have been left sitting face up or even left out at all on someone's desk?

Credit apps, where are your deal jackets? Are they stored? Are they locked away? Are they in areas where customers or someone else from the public can walk by? Those are all key Things that need to get written down in a ball.

Go buy a shredder, run out to Costco, get yourself a sturdy shredder.

You know, shredding services where you have put them in the box and they come pick it up.

That's what we do. We have that, we have that monthly. I think that's a big step, an easy step. You know, $59 a month can fix that problem really quickly. What. So Earl, this is, this is for you because, you know, you're, you're the guy that's going to try to keep us all out of trouble. If for some reason we do get in trouble, I mean, what are the consequences? You know, what's going to happen?

So like I mentioned before, one of it you could end up on the news. The FTC can fine you $46,517 per consent order violation. And one record could be a violation. So that could pile up extremely quick. The dealership I worked for before law school actually just got sued private right of action for $5 million based on data breach where they didn't inform the people and they didn't take the right precautions after occurred. And they're looking at $5 million lawsuit.

Wow, that's, that's pretty steep. I saw that in the news the other day. And that's, I mean, so, you know, we hear this when it comes, you know, the Democrats are always complaining about we don't have enough IRS agents like the back taxes and we're not going after the rich people and worried about audits in them. I mean, does the ftc, are they ramping up their, their staff and for their enforcements? I mean, what's going on there, you think?

So the FTC for a while, when this passed, initially this past three, two. There's five commissioners on the board. But then they, they let, they ran this right before it passed and then they promoted that person to the cfpb. So they were at Tutu. So for a while there's been kind of a pause on any type of action. Now they're back up to five. So it's kind of a wait and see what they're going to do. But if you look at everything they're making a priority. Privacy laws are one of the top ones. They have identity theft rules that they're working on. Children's Online Privacy Protection act, they're working on. So they're working on privacy stuff right now. And they have the five people on the board, whereas before they were at 2, 2. And they couldn't really do what they wanted to do policy wise.

So it's like most things, when there's, you know, maybe a Democratic leaning majority and president, you may get more enforcement and more of this, but if it goes other way, maybe a little less is that. And of course, we're in a Democratic held government at the moment, so that's the reason this has happened, I will assume.

Okay.

So, Jeff, it makes me think about.

Like the other day, we had a customer come in and she was a little off a rocker, but a little upset that she thought that we had given her personal information to other people because she was under the impression she had credit inquiries from who knows what. Right. And we don't know what this lady was doing. She was probably shopping around for cars. She probably visited five dealerships, and she wanted to think that it was us that had breached that confidence. And so part of all of this is making sure your salesmen and those interacting with the customers know exactly what to say to diffuse those situations and guide those people that might have a little bit of a bee in their bonnet might send them a different direction, you know, Mr. Customer. No, here is our policies for personal information. You filled out a credit app. It went into our system. The credit app got shredded. Your driver's license got shredded. We have none of your personal information sitting around. You don't have to come back here and try to take your credit app with you because you think we're gonna go sell it out the back door to five different people, like some of that weird stuff. And if your salesmen don't know how to respond to that and they him haw around, that leaves the door open for that customer to be like, wait a minute, something weird is going on here. They can't give me a straight answer on what happened to my personal data.

That brings up a great point. Jeff. Greg, do y' all train on that at the dealership?

Yeah. You know, and that's one of the kind of the continuous and ever evolving policies we have is, you know, we try to train on everything. And one of those being how salesmen communicate certain rules to customers. You know, whether it's this part with credit reports or public information, what we access to look into customers to determine their risk profile. Yeah, I mean, we just. We need to constantly train our sales team on that, especially with turnover, just so we have clear communication with customers.

And even, I mean, can we even put in a process of salesmen not talking to customers about this? I mean, shouldn't this be someone maybe higher up, Greg. Or is this Committee ahead of the front line.

When it gets into the details, it gets to me. And I'll reach out to the customers or my assistant Olivia will, because, you know, you don't want salespeople saying the wrong thing or, or kind of taking the wrong tone because it can get a bit nuanced. But we do want to train the salespeople and the general idea of things, what to say, and at least give them a chance to talk to the customer about it. But if, you know, if they want to get into details, and especially if a customer is angry or upset or otherwise emotional, then it'll get sent to me immediately.

And that'd be my question for you, Earl. We're never going to be perfect, right? I mean, our dealerships are not going to be perfect. Even someone like Greg's organization that has counsel and training and this, that and the other, something could happen, something could slip through. There could be some sort of a breach. And when the FTC comes in or an attorney comes in, or whoever comes in to crack down and get mad and yell and scream and try to find you, so much of this to me seems like at least you've got something on the books, right? If they go in and they see that you have nothing, you have no policies, you have nothing written, you have no existence, no shredder, no documents, no two factor, that's a bad situation. If you have something and you're like, look, we got policies and we've tried to train and we've tried to do this, it seems like you're going to be a lot, lot better off. Even though we can never be perfect.

You'Re not expected to be perfect at the end of the world. What they expect you to do is take every reasonable precaution based on, I mean, that's the key to be able to show that, hey, I've done everything within my power to avoid this. Because at the end of the day, there are government systems that have been breached. So if that's happening, there's no way a dealership's going to be able. Especially if you're only a small 5 to 20 car a month dealership. How are you supposed to do that? There's no way to prevent 100% of all hacking.

Yeah, I mean, you look at, I mean, the state of South Carolina several years ago, all our data was stolen, all the people who had filed taxes, all their data was stolen. And so, I mean, that's a government that runs, you know, billions of dollars a year. And this is, this is what happened so that's. I mean, something's better than nothing, I guess. And what's great is, Tiada, you're doing things to help dealers. And I've taken the course. I found it very interesting. It wasn't that long, and it was. It was something that made me think about everything we were doing. Earl, can you talk about what Tiaa Tiada has done to help us?

So a couple things. We did the course. There's a model policy in there. There's. Greg was talking about the agreement between his vendors. We create a model agreement, too, so it can help dealers. Because not everybody has counsel. We get that. And we want to kind of keep the cost down because the estimates of the cost of implementing some of the requirements was extremely high. We felt these were items that can give a dealer a good starting point and kind of get them on the way. The other big thing we've done, we have the FTC come to our conference. We were able to get one of the attorneys out of Dallas. He's coming down, and he's going to talk about the safeguards rules to our dealers. He's also going to talk about the buyer's guides as well. So those big ones.

Well, yeah. And the course pricing is not that expensive for what you get, I don't think. Can you talk about the pricing and the pricing structure for larger dealership groups?

So if you're a large dealer group and you do more than 10. So if you have more than 10 employees and you sign up, it's $40 per course is 49 for the regular employee. And then there's a qualified individual course, which is 79. And it has the model policies in it and has a lot more information than just the employee one. Because there's certain things that the qualified individual needs to know that your regular salesperson does. Not much. As Greg was saying earlier, I think there's certain times where he just needs to go to the qualified individual. You shouldn't have them deal with every single item. And for those items, we took it out of the course because time is so important at the dealership. We want to make sure you only got the information you need it and didn't spend a bunch of time wasted on that.

Yeah, it looks like you got Tom Carter. Is that the guy? The FTC from Dallas? He's speaking at the conference. And when is the conference? Because we're getting right up on this thing.

July 24, 26. Our early bird ends June 17.

Okay. We will be there and we'll have.

A lot of fun. The IADA conference is great. It is great. It is great. Doesn't matter if you're not a Texas dealer, right, Earl? If anyone's outside of Texas gets their hands on this podcast and listens, can they still come?

Certainly. And as long as you're a member of your state association, we treat you just like one of our members. With the other associations, we always feel like, well, we're fortunate being Texas because of our size. We have a little more resources and are able to offer a little more than some of the others can.

And one other thing. I think I was told that Texas TIADA put this together, this course together, and it's good for every state in the union. I'm in South Carolina and I think actually my association may even get a kickback from me taking it. Is that correct, Darrell?

That's correct. We did share because we want to support the smaller associations. We feel it's important. And this is based on federal law, so there's no difference in Texas than there is in South Carolina because it's all federal law based. Now your, your state may have additional stuff that they require that's not related to this rule, but overall, this is a federal law, so this is 100% good anywhere.

So, Greg, I assume you've taken this course, correct?

Yeah, absolutely.

What do you think about it? What was your, what did you come away with? You're. You're an attorney, you, you know what to look for here. I'm just an old car dealer. I thought it was great. So let's hear your side.

Yeah, I thought it was good. You know, the qualified individual course is approximately an hour long. It had good substance. You know what I was really impressed with was the all employee course, about 30 minutes. And it really strikes the right balance between length and substance. As you guys know, a lot of the people on our lots and on the ground that deal with non public information have to multitask all the time. You got collectors, you got salespeople, and you have admin, support, functions, accounting, everything else. And so it can be hard for them to get an hour or two hours out of a straight out of a day just to commit to a training. And so I think the tiada's course here has just been great because not only does it provide the substance you need and the knowledge, but it's down 30 minutes plus you get a quiz at the end to make sure that you retain the information. So it really hit the sweet spot there and we're happy to have it and implement it in our company.

Yeah, I made 100 on my quiz. Jeff, have you taken the quiz yet?

I'm still studying. I had to get a tutor in order to do it. But to that point, Luke, we talk about it. We know that everyone listening to this is training weekly anyways, right? Wink, wink. Everyone's out there training their staff weekly on something, whether it's sales, collections, all the things we're training. This is a great one to add in there. It's so smart to have this every quarter or annually or whatever the cadence needs to be for your dealership.

And this is an annual thing, correct, Earl? Is that. Is that right, Andrew? Training.

So we set it for annual. The FTC requires a continuous training program. They are very specific on what that regular training is under their definition. We feel years about reasonable. As fast as a guidance, though, and.

You know, as fast as technology changes in today's society, you know, tomorrow we might be accepting dogecoin as payment. Who knows, you know, and, you know, whatever. I don't think so. But Jeff is highly leveraged in dogecoin. And so you just never know what new technology is going to come out next year to make safeguards easier or harder. So we've got to stay trained on everything, like Jeff was saying.

Yeah, well, we know identity theft, we know fraud, we know cyber attacks, we know all that is on an exponential rise. You know, the posts that we get from dealers talking about fake pay stubs and even fake buyers and fake IDs. It's just, it's getting worse and worse and worse because the technology is getting better and better and easier to fake all this stuff. You know, it's just. So, yes, we've got to stay a step ahead or at least on par with some of the craziness that's going on out there. Let's have closing arguments. Earl, give us real quick your final pitch to dealers. Advice, input, what do we. Why do we need to stay on top of this?

You know, compliance affects the bottom line. At the end of the day, you have to realize if you're not compliant, it is kind of flashy because, you know, when you're not compliant, you end up on the news, you end up in a lawsuit, you end up having to pay money out. So, you know, yes, sales, you see, because it adds to the top line. But, you know, at the end of the day, nothing can hurt you worse than a lawsuit. I mean, it gets very expensive, very quick, and just doing stuff like this can hopefully avoid those items.

And Greg, what's. What do you say?

I think Earl hit the nail on the head there. I mean, it's just, it can get very expensive very quickly and it's going to spend a lot of time, resources, employee hours, you're getting to the bottom bit, trying to fix it. And so being proactive, getting out in front of it, getting these written policies and procedures in place and kind of mitigating as much as possible will help you in that unfortunate event. If something happens, you know, cross your fingers and pray that nothing does happen and you'll be safe. And you know, it's, at least your employees are going to be knowledgeable and because there's always going to be things that they're going to need to do on a daily basis, even if a hacking doesn't happen. Right. So I mentioned earlier, when you're, when they're, who they're giving out personal information to, whatever, so there's always going to be knowledge is needed here, even if it's a minor issue. But as far as, you know, mitigating those big issues and there's just really expensive issues, it's just incredibly important.

It's, it's something as easy as walking around your dealership that was said during the, the, the discussion. Walking around, open your eyes looking for things that you go that shouldn't be sitting there. It's that simple. And these things are just as important as buyer's guys, right, Jeff?

Yeah. It's funny. I'm involved in another organization that has two or 300 employees and they recently hired a security firm to try to attack them and try to get into their network. And also physically, these guys came to different locations and physically tried to gain access to the buildings, which they were successful on one, the police showed up and like arrested them. It was this crazy thing. But, but to look at our dealerships the same way from an outsider standpoint, or look at it as a thief, you know, are my door secured? Is my data room secured? Are my files locked up? Does that lock even work? You know, are my computer shut down every single night? And all these kind of look at it from the outside. And Luke, my closing argument, I go back to the beginning. It's really the golden rule. Do unto others as you would have them do unto you. Right. My thought is, I mean, just recently I'm emailing my banker and underwriter my tax returns and my personal documents and my personal financial statements. If this guy's sitting on a beach in Mexico on an unsecured network and he leaves his laptop open to go grab a frigging pina colada or something. Like all my stuff's right there and it's gone. So it's crazy. We should never, never do what we wouldn't want people doing with our personal data.

Treat your identity and your customer's identity just the same. And I think everybody will be just right.

Guys, we look forward to seeing you in July down in Austin. Right. TIADA Convention. We look forward to hearing from Tom Carter. And we're all going to jump on the TIAD website and get our training done.

Yes, sir.

Rick. All right, guys, thanks so much for your time.

Thank you.

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