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MRAA Rewards Credit Card Auto Processing Form
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The Automatic Credit Card Charges Form accessible through this page contains personal information about the consumer, along with sensitive credit card information (number, expiration date, security code). Therefore, while the form may be permissible, you, as the dealer, will need to make sure that your business has a Red Flags document protection process and strictly enforces this process to reduce the risk of liability. This kind of form would be a gold mine for identity thieves or anyone tempted to steal. Also, this form may violate your merchant agreement if the merchant agreement expressly forbids charges without specific authorization from the consumer. Lastly, you should have a process to address situations where consumers dispute charges incurred in this fashion.

The process and proper disclosure that the MRAA recommends includes:

  • You should secure forms and limit access by employees or individuals not affiliated with the business in a fashion consistent with applicable state and federal law.
    -- This includes document retention rules and the dealership’s individual Red Flags compliance program
  • Your dealership should limit individuals who are authorized to charge the consumer’s credit card.
  • Manager authorization should be required before the consumer’s credit card is charged by an employee, with documentation showing the manager’s authorization, and the employee who charged the card (if different from the manager).
  • Dealer should verify with its merchant agreement that this kind of automatic charge does not violate the Terms of Service ("TOS”) of the merchant agreement.
  • Dealer should reconcile automatic charges by consumer to outstanding balances and establish other processes to detect fraud.
  • Provide additional notice to consumer, in the form of an invoice with a statement that, if not paid within X days, pursuant to the Authorization Agreement on file, the balance due will be charged to the credit card on file.

MRAA’s disclosure: Before implementing any processes, please refer to the business’s merchant agreement’s TOS to verify that this type of activity is allowed. MRAA makes no representations nor warrants that this form is permissible for use in your state.

Download the form now.