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© 2009 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
© 2009 Car-Part.com 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
© 2009 Car-Part.com 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
© 2009 Car-Part.com 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).
© 2009 Car-Part.com What Information are Auto Recyclers Required to Report? In the monthly report, auto recyclers must provide the following information: –The yard or recyclers name, address, and contact information for the reporting entity –The vehicles 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
© 2009 Car-Part.com 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.pdfwww.nmvtis.gov/Data_Required.pdf –AAMVA Overview – www.aamva.org/GovAffairs/IssueWatch/NMVTIS/ www.aamva.org/GovAffairs/IssueWatch/NMVTIS/ NOTE: See Reporting by Junk Yards, Salvages and Insurers to NMVTIS and Attachment A.
© 2009 Car-Part.com 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
© 2009 Car-Part.com 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.
© 2009 Car-Part.com 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.
© 2009 Car-Part.com 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.www.add123.com –Insurance Services Office, Inc. (ISO) (www.iso.com) was announced by AAMVA as an authorized data consolidator on March 19, 2009.www.iso.com
© 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 non- commercial purposes.
© 2009 Car-Part.com 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.
© 2009 Car-Part.com 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 Car- Part.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.govwww.nmvtis.gov –AAMVA – www.aamva.org/GovAffairs/IssueWatch/NMV TIS/ www.aamva.org/GovAffairs/IssueWatch/NMV TIS/ –ARA – www.a-r-a.orgwww.a-r-a.org –Auto Data Direct, Inc. – www.add123.comwww.add123.com –Insurance Services Office, Inc. – www.iso.comwww.iso.com
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