At OADA's urging, the Ohio Attorney General reviewed the information 700Credit provided to dealers regarding its breach to provide clarity whether dealers have an obligation to notify consumers under Ohio law. After discussion with OADA, we are pleased that the Ohio Attorney General will allow 700Credit to provide notices to affected consumers in lieu of notices coming from individual dealers. The Ohio Attorney General has stated that in this specific instance, it will adopt the same posture as the FTC. So long as 700Credit provides at risk individuals with notice appropriate under Ohio law, individual dealers are not obligated to provide duplicate notice to those same persons.

OADA appreciates the Ohio Attorney General's consideration and prompt review of this issue.

OADA continues to recommend that dealers speak with counsel and their insurance providers, proactively take steps to protect customer information, review your vendor contracts, and monitor your vendors to ensure they take appropriate steps to protect consumer information. For additional guidance, please review our previous alert.

We will continue to provide additional information as it becomes available. Please contact Sara Bruce, Vice President of Legal Affairs, at sbruce@oada.com or 614-923-2243, or Matthew Smallwood, Staff Counsel, at msmallwood@oada.com or 614-923-2232, with any questions.