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This page is an archive of previously-published content. The information was accurate at the time it was published; however, the information may no longer be accurate or complete. If you have any questions about current Car-Part products, please contact your sales or support rep.
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| Volume 02 - Issue 7 |
April 14, 2009 |
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NMVTIS Reporting
The National Motor Vehicle Title Information System ("NMVTIS") reporting rules for auto recyclers went into effect on March 31, 2009. These rules require auto recyclers to provide a monthly inventory report regarding all of the junk and salvage automobiles obtained in the prior month. The inventory report must include the following information for each such automobile:
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the name, address, and contact information for the reporting entity;
VIN;
the date the automobile was obtained;
the name of the individual or entity from whom the automobile was obtained; and
a statement of whether the automobile was crushed or disposed of, for sale or other purposes, to whom it was provided or transferred, and if the vehicle is intended for export out of the United States. |
The American Association of Motor Vehicle Administrators ("AAMVA"), the operator of NMVTIS, has decided that it will not collect the required data directly from auto recyclers. Auto recyclers are required to submit their inventory reports to NMVTIS through one of the data consolidators designated by AAMVA. The Department of Justice ("DOJ"), the agency responsible for administering NMVTIS, has announced that it will require AAMVA to designate at least 3 data consolidators. At this point, only two such data consolidators have been designated by AAMVA to date: Auto Data Direct, Inc. ("ADD") and Insurance Services Office, Inc. ("ISO"). It is anticipated that at least one more data consolidator will be announced by the end of May. We understand that both ADD and ISO offer fee-based NMVTIS reporting services for auto recyclers.
The National Salvage Vehicle Reporting Program ("NSVRP"), a reporting program being administered by Howard Nusbaum, has indicated that NSVRP participants will have their data submitted in to NMVTIS reporting obligations for no per-transaction cost (although NMVTIS has indicated that it expects ISO, the data consolidator to be used by participants in the NSVRP program, to charge an initial setup fee and a yearly renewal fee) if they provide the information required to be reported under the final NMVTIS rules (along with certain other information designated by the NSVRP) to the National Insurance Crime Bureau ("NICB"). NICB is permitted to use the information submitted pursuant to NSVRP for law enforcement, anti-fraud, and other unspecified non-commercial purposes.
We recommend that auto recyclers contact ADD, ISO and NSVRP directly for more information on their respective fees, reporting methods, technical specifications and their respective timeframes for being able to begin submitting auto recyclers’ inventory reports into NMVTIS.
The DOJ has repeatedly indicated that its initial focus regarding NMVTIS reporting will be on compliance and not on enforcement. In an NMVTIS update posted on the www.nmvtis.gov website on March 13, 2009, the DOJ: (1) recognized that the reporting mechanisms may not be in place and/or operating in a manner to allow the required NMVTIS reporting by auto recyclers by March 31, 2009; and (2) indicated that an auto recycler should file the required data with respect to all junk and salvage automobiles obtained on or after March 1, 2009 even if their initial report is delayed after the March 31, 2009 date referenced in the NMVTIS rules. We cannot assure you that the DOJ will not change its position with respect to focusing on compliance rather than enforcement (or provide you guidance regarding when the DOJ will begin focusing more intently on the enforcement provisions relating to the NMVTIS rules), however, we currently believe that auto recyclers should not be overly concerned if its their initial NMVTIS reporting is delayed for a period after March 31, 2009 (so long as the auto recyclers are prepared to report the required data with respect to all vehicles acquired on or after March 1, 2009 when they makes their initial NMVTIS reports).
Auto Recyclers can obtain more information regarding NMVTIS:
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Did You Know?
Registration for the sixth Annual Checkmate Users Group meeting and this summer's Car-Part training is now available online! Just go to https://products.car-part.com/training/ for more information or to register. |
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Car-Part.com's NMVTIS Efforts
Car-Part.com has been working hard on behalf of auto recyclers to minimize both the cost and administrative burden associated with meeting their NMVTIS reporting obligations. Car-Part.com and ARA Services Corporation, a joint venture between the Automotive Recyclers' Association ("ARA") and Car-Part.com, have agreed to work together in an effort to assist auto recyclers in complying with their NMVTIS reporting obligations. ARA Services Corporation has been in regular communication with the AAMVA and the DOJ in an effort to be designated as an authorized data consolidator. It is ARA Services Corporation's desire to become an authorized data consolidator as quickly as possible and to provide an NMVTIS reporting service free of charge to all Car-Part.com web services customers that authorize Car-Part.com to forward VIN data to ARA Services Corporation (provided that ARA Services Corporation is not required to pay a fee to AAMVA or any other party in order to serve as a data consolidator). ARA Services Corporation intends to offer an NMVTIS reporting service that will: |
- be fully-automated and integrated within many inventory management systems (including Checkmate, Fast Parts, Hollander, Powerlink I, Powerlink II, Pinnacle Classic, AIMS, and ISoft);
- provide auto recyclers the ability to choose to report only the minimum information required by the NMVTIS rules;
- provide auto recyclers the ability to choose to report only the information relating to junk automobiles or salvage automobiles obtained on or after March 1, 2009; and
- protect the data of auto recyclers from being used in a manner that is not in the best interest of auto recyclers.
Car-Part.com already collects most of the information that is required to be reported under NMVTIS in its standard inventory upload process. Car-Part.com is also already in the process of modifying its inventory upload process to include all of the information that is required to be reported by auto recyclers under the NMVTIS rules. We currently expect that the inventory upload processes will be updated on all inventory management systems supported by Car-Part.com to collect all required NMVTIS data by the end of April. AAMVA has recently advised us that they do not expect to designate another data consolidator until late May.
As an interim step, Car-Part.com has developed reports for Checkmate and Fast Parts customers that will allow them to extract the required NMVTIS data into a CSV (comma separated values) file as required by the National Salvage Vehicle Reporting Program ("NSVRP"). These reports are currently undergoing the final stages of beta testing and will be available to Checkmate and Fast Parts customers in the near future. Checkmate and Fast Parts customers will need to contact either Auto Data Direct, Inc. ("ADD") or Insurance Services Office, Inc. ("ISO"), the current authorized data consolidators designated by AAMVA, or NSVRP for instructions on: (1) how to obtain an NMVTIS reporting entity identification number (only ADD and ISO are currently in a position to assign such numbers); and (2) what to do with the CSV file in order to allow ADD, ISO or NSVRP to make the NMVTIS reporting on behalf of such recycler. Detailed instructions regarding which fields to enter the required NMVTIS information into for the various inventory management systems and how to run the Checkmate and Fast Part reports described above will be provided to all Car-Part.com customers in the near future.
With the reports described above, Car-Part.com will provide Checkmate and Fast Parts customers the ability to currently file the required NMVTIS reports through one of the authorized data consolidators (ADD or ISO) or by participation in the NSVRP program. However, if an auto recycler is not satisfied with any of the NMVTIS reporting options that are currently available they may also choose to wait until additional data consolidators are designated by AAMVA. We cannot assure you that the Department of Justice ("DOJ") will not change its current position of focusing on compliance rather than enforcement (or provide you guidance regarding when the DOJ will begin focusing more intently on the enforcement provisions relating to the NMVTIS rules), however, we currently believe that it is unlikely that the DOJ will penalize auto recyclers that choose to wait until an additional data consolidator is designated to make their initial NMVTIS reporting.
Car-Part.com intends to keep its customers informed of new developments relating to the NMVTIS reporting (including any announcements or decisions by AAMVA regarding the authorization of additional data providers). We will be posting NMVTIS reporting updates on the ARASC VINS tab of the https://products.car-part.com website. If you have any questions regarding NMVTIS reporting, please contact your support rep or email the questions to NMVTISReporting@car-part.com
©2009 Car-Part.com. All rights reserved.
All trademarks are the properties of their respective owners.
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