E-Odometer and E-Title Region III Information Exchange October 2016

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1 E-Odometer and E-Title Region III Information Exchange October 2016 Casey Garber, Manager Vehicle Programs, AAMVA

2 What is the status of Electronic Odometer (E-OD) Disclosures? How we got here. What we have done so far. What was required in the Notice of Proposed Rulemaking (NPRM)? The approach the E-OD Task Force is taking. What are the next steps?

3 Julie Larsen, Chair, Florida Donna Brouch, California Karen Grim, Virginia Thomas McCormick, Vermont Clint Thompson, Texas Kay Kishbaugh, Pennsylvania Andrew Lewis, Iowa Scott Clapper, Delaware Michael McCaskill, Florida Stacey Rockwell, Iowa Paul Nilsen, Wisconsin Joann Loehr, Montana Joseph Hill, Virginia

4 In 2010, AAMVA members approached the board with an interest to develop best practices for e-titling. As a result the E-Titling Working Group was established. October 2013, the E-Title Task Force closed the Proof of Concept issuing multiple deliverables that are on the AAMVA website today. In closing the project, the task force decided to re-direct efforts to solving the E-Odometer challenge in order to move toward an electronic title solution. The Task Force began meeting by weekly conference calls in January 2014 and have held four face-toface meetings, one including stakeholders, to determine the best way to move forward with an e-odometer solution and will hold another in November In August 2011, the E-Titling Working Group asked the Board to approve a Task Force to work on a Proof of Concept for a memberdriven electronic titling program to pilot electronic titles from the time they are manufactured until they are titled. The Board approved the project. The E-Odometer Task Force was subsequently formed in January 2014 to evaluate the TIMA requirements and strategize recommendations or considerations for implementing an electronic odometer disclosure program.

5 .. The Task Force developed a E- Odometer Task Force White Paper Report in December 2014 in anticipation of the Federal Regulations. On December 4, 2015 the President signed the FAST Act. It authorized states to accept electronic odometer disclosures without NHTSA approval. This authority under the FAST Act terminates once NHTSA promulgates its e- odometer regulation. On March 25, 2016 NHTSA issued a notice of proposed rulemaking (NPRM) Odometer Disclosure Requirements for public comment. The comments are due no later than May 24, This NPRM attempts to allow electronic odometer disclosures while maintaining and protecting the existing systems that ensure accurate odometer disclosures and aid law enforcement in prosecuting odometer fraud. NHTSA has made a preliminary determination that at least a National Institute of Standards and Technology (NIST) Level 3 verification of electronic signatures should be required. Proposed changes for exemptions: NHTSA currently exempts any vehicle which is more than 10 years old from odometer disclosure requirements. NHTSA proposes to raise this exemption to 25 years and requests comments on whether this exemption should be eliminated. 28 comments were received from associations, industry, states, insurance companies, and AAMVA. Five states commented on the NPRM.

6 Electronic records be retained in a format that cannot be altered Electronicrecords indicate any attempts to alter it Each individual person be uniquely identified by their own unique electronic signature If the individual is acting in a business capacity or on behalf of any other individual or entity, that the business or entity also be identified as part of the unique electronic signature Any requirement to disclose, issue, execute, return, notify, or otherwise provide information to another person is satisfied when a copy of the electronic disclosure or statement is electronically transmitted or made accessible to the party required to receive the disclosure Any physical documents used to make electronic disclosurescomply withexistingapplicablerequirements Once an odometer disclosure is incorporated in the electronic title, the electronic title containing the disclosure is the official record of ownership and mileage. The electronic disclosure does not continue as a record separate from the electronic title If an electronic title containing an odometer disclosure must be converted to a paper document as the official document, only a state or state-authorized entity can create the new official document. Further the paper document must be set forth by means of a secure printing method as a physical, paper document Allows states to authorize the issuance of some type of record of ownership document that would contain the information on a title and/or odometer disclosure but would not replace the official document and clearly indicate that it is not an official title or odometer disclosure Requirements on conversion of paper title to an electronic system, including that prior title be copied electronically for retention and that paper title be destroyed at the time of conversion to electronic documents. Scanned documents must provide a resolution of 600 dpi to ensure preservation of security features during conversion

7 The Guidance Document the Task Force is currently drafting includes the following general topical areas which consider the subjects discussed in the December 2014 White Paper, the NPRM and comments received. Administration Benefits Title Requirements & Reassignments Identity Standards & Electronic Signatures Official Document Printed Name Enforcement & Fraud Deterrence Leased Vehicles Scanning Notaries Legislation & Rules

8 Title Process States Buyers & Sellers Electronically Exchange Data

9 Tasks Survey Jurisdictions Regarding Electronic Processes and Analyze Responses Submit Comments To NHTSA s Notice of Proposed Rulemaking Odometer Disclosure Requirements Draft a Guidance Document for Implementing Electronic Odometer Disclosure Program Milestone Timeframe March and April 2016 March - May 2016 May - November 2016 Submit Guidance Document to AAMVA Committees and Board for Review Process Modify Guidance Document based on comments. Winter 2016 January March 2017 Publication of Guidance Document Spring 2017

10 For More Information Contact: Casey Garber, Manager of Vehicle Programs