Transcript Car-Part.com

Overview of Auto Recyclers’
Reporting Obligations under the
National Motor Vehicle Information
System (NMVTIS)
© 2009 Car-Part.com
What is NMVTIS?
• An information system intended to enable states and others
to access automobile titling information
• Purpose of NMVTIS:
– To prevent the introduction or reintroduction of stolen motor
vehicles into interstate commerce
– To protect states, consumers (both individual and commercial), and
other entities from fraud
– To reduce the use of stolen vehicles for illicit purposes, including
funding of criminal enterprises
– To provide consumers protection from unsafe vehicles
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What is NMVTIS?
• Established under the Anti-Car Theft Act of 1992
• The Anti-Car Theft Act Improvements Act of 1996
transferred responsibility for administration of the act to
the Department of Justice
• The final NMVTIS rules were published by the
Department of Justice in the Federal Register on January
30, 2009 (28 CFR Part 25)
• The NMVTIS rules require reporting of certain
information by insurance carriers, auto recyclers, junk
yards, salvage yards, salvage pools, scrap metal
processors, and shredders
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Who operates NMVTIS?
• The Department of Justice is responsible for
administering the NMVTIS program
• The Department of Justice has designated the
American Association of Motor Vehicle
Administrators (AAMVA) as the operator of the
NMVTIS system
• AAMVA has indicated that they will not directly
collect the required information, but will designate
data consolidators to collect this information and
report the data to the NMVTIS system
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What are the NMVTIS Reporting
Requirements for Auto Recyclers?
• Junk yards and salvage yards in the US
must provide NMVTIS with a monthly
inventory of all junk and salvaged
automobiles obtained in the prior month.
• The terms “junk yard,” “salvage yard,”
“junk automobile,” “salvage automobile,”
etc. are defined in the official NMVTIS
rules (28 CFR § 25.52).
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What Information are Auto Recyclers
Required to Report?
• In the monthly report, auto recyclers must provide the
following information:
– The yard or recycler’s name, address, and contact
information for the reporting entity
– The vehicle’s VIN
– The date the automobile was obtained
– The name of the individual or entity from whom the
automobile was obtained
– Information about the disposition of the vehicle –
whether it was crushed, disposed of, sold, transferred,
or exported out of the US
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What Information are Auto Recyclers
Required to Report?
• If a recycler does not know the disposition of a vehicle at
the time the initial report is submitted, recyclers may be
required to file an update when the disposition is known.
• Both the DOJ and AAMVA have prepared overviews of
the reporting requirements for auto recyclers
– DOJ Overview – www.nmvtis.gov/Data_Required.pdf
– AAMVA Overview –
www.aamva.org/GovAffairs/IssueWatch/NMVTIS/
NOTE: See Reporting by Junk Yards, Salvages and
Insurers to NMVTIS and Attachment A.
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When do the NMVTIS Reporting
Requirements go into Effect?
• Auto recyclers have been required to provide
inventory reports since March 31, 2009.
• In a March 13 notice posted on the NMVTIS
website, the DOJ all but acknowledged that the
reporting mechanisms may not be in place to
allow for reporting on March 31 and that initial
reporting may be delayed.
www.nmvtis.gov/Notice%20Regarding%20Reporting%20Requirements.pdf
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When do the NMVTIS Reporting
Requirements go into Effect?
• In the same March 13 notice, the DOJ also indicated that
“the initial report, when submitted, shall include all
automobiles with regard to which the reporting
requirements of sections 25.55(a) and 25.56(a) of the
NMVTIS Regulation were satisfied during March 2009.”
• NMVTIS reporting requirements apply to vehicles
obtained on or after March 1, 2009 regardless of when
your initial report is made.
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When do the NMVTIS Reporting
Requirements go into Effect?
• In an update on March 18, 2009, ARA indicated that
“[b]ased upon feedback received from the DOJ, it appears
that, until there are two data consolidators available for
collecting data for NMVTIS, the Department will probably
not consider the NMVTIS program in a position to require
any reporting of data by automotive recyclers into
NMVTIS.”
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How can Auto Recyclers
Report the Required Information?
• AAMVA has indicated that they will be
designating authorized data consolidators to
collect the data
– Auto Data Direct, Inc. (www.add123.com) was
announced by AAMVA as an authorized data
consolidator on March 4, 2009.
– Insurance Services Office, Inc. (ISO)
(www.iso.com) was announced by AAMVA as
an authorized data consolidator on March 19,
2009.
© 2009 Car-Part.com
How can Auto Recyclers
Report the Required Information?
• NSVRP, a reporting program being administered by
Howard Nusbaum, has indicated that due to the
existing relationship between NICB and ISO,
NSVRP participants will be able to meet their
NMVTIS reporting obligations if they agree to
provide the required information to the National
Insurance Crime Bureau (NICB).
• NICB is then permitted to use the information
submitted by NSVRP participants for law
enforcement, anti-fraud, and other unspecified noncommercial purposes.
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What are ARASC and Car-Part.com doing
with respect to NMVTIS Reporting?
• ARASC has been in regular contact with AAMVA and
DOJ in an effort to be designated as an authorized data
consolidator.
– AAMVA has indicated that they are initially only working with Auto Data
Direct, Inc. and ISO but that they will be seeking to designate additional
data consolidators in the near future.
– DOJ has consistently indicated that they will require AAMVA to designate
at least 3 data consolidators.
– AAMVA has indicated that they would ultimately like to have at least 4-5
data consolidators.
– ARA has indicated that it will continue to push DOJ to have AAMVA
provide opportunities for as many third-party data consolidators as is
reasonably acceptable to help ensure a minimal cost compliance option.
© 2009 Car-Part.com
What are ARASC and Car-Part.com doing
with respect to NMVTIS Reporting?
• ARASC would like to become an authorized data
consolidator so that it can provide an NMVTIS reporting
service to Car-Part.com web services customers that
authorize Car-Part.com to forward their VIN data to
ARASC.
• Car-Part.com already collects some of the information that
is required to be reported under NMVTIS in its standard
inventory upload process and is currently modifying its
inventory upload process to include all of the necessary
information.
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What are ARASC and Car-Part.com doing
with respect to NMVTIS Reporting?
• Advantages of ARASC NMVTIS Reporting Service:
– The process of filing your monthly NMVTIS reports could be
automated (Car-Part.com is modifying its upload software to
collect the required information).
– We expect that this service will be provided at no cost to CarPart.com web services customers that authorize Car-Part.com to
forward their VIN data to ARASC.
– Auto recyclers could choose to report only the information that is
required under the NMVTIS rules.
– Data would be protected – the information would be reported
directly to an authorized data consolidator.
– ARASC data feed revenue is shared with ARA, so this would
benefit auto recyclers.
© 2009 Car-Part.com
What are ARASC and Car-Part.com doing
with respect to NMVTIS Reporting?
• Car-Part.com is currently beta testing the new inventory
upload process for Checkmate, Fast Parts, and Hollander.
• Car-Part.com will be beta testing the new inventory upload
process for Powerlink I and Powerlink II soon.
• Car-Part.com still has development work to do on the new
inventory upload process for Pinnacle Classic, AIM, and
ISoft.
• Car-Part.com expects to complete beta testing on
Checkmate, FastParts, Hollander and Powerlink I in April.
• Car-Part.com also hopes to complete beta testing on
Powerlink II, AIM and ISoft in April.
© 2009 Car-Part.com
Additional Information
• ARASC and Car-Part.com will be providing
updates as new information becomes available
• Websites
– DOJ – www.nmvtis.gov
– AAMVA –
www.aamva.org/GovAffairs/IssueWatch/NMV
TIS/
– ARA – www.a-r-a.org
– Auto Data Direct, Inc. – www.add123.com
– Insurance Services Office, Inc. – www.iso.com
© 2009 Car-Part.com