NMVTIS Saves the Day

NMVTIS (National Motor Vehicle Title Information System - pronounced En-Em-Vee-Tis) is a data system that stores information about titles issued by each of the 50 states plus DC. States are required to both submit data about their titles to NMVTIS and check NMVTIS to verify titles being transferred from other states. The US Department of Justice has ruled that all states must participate by January 1, 2010. (That ruling provides background about the laws requiring the system be developed and requiring participation.)

Some businesses are also required to provide data about vehicles, including insurance carriers and junk/salvage companies. The website at NMVTIS.gov provides more information about compliance.

For lenders, this has a few implications:
Public inquiry of the NMVTIS records are available.
DDI has chosen to use Auto Data Direct as a provider of NMVTIS inquiries and will be integrating those titling records with Premier eTitleLien™.

There are two main benefits to lenders. First, the NMVTIS records should show the most recent title issued as well as a history of other titles (and states who issued them) for the VIN. Second, NMVTIS contains a record of all the brands (salvage, flood damage, etc) that have been applied to the vehicle and which state applied them. NMVTIS does *not* include lien information.

State processes may change slightly.
At DDI we have observe two significant impacts to lenders as states are complying with NMVTIS. First, NMVTIS has its own data requirements that may not match each state. For instance, different states have different kinds of vehicle brands, and there is not a national standard for brands. More significantly, the NMVTIS standard for VINs has resulted in some states changing the VINs on their titles. (Mobile Homes have VINs that do not match modern automobile VINs - they frequently are recorded as 12345678A&B which is invalid.) This can cause problems for lenders releasing liens or trying to find information about a title.

Second, implementing NMVTIS into the business process for the state may delay issuing a perfected lien by up to five days. Any title received from out of state should be checked against the NMVTIS record to check for issues. A state may choose to slow down the process to be sure NMVTIS was updated. This should help reduce fraud and errors when transferring titles between states.

For more information about how each state participates in the NMVTIS program, see the official NMVTIS website. For more information on how Premier eTitleLien™ helps lenders cut costs and reduce fraud, see our official website. ;)

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Premier eTitleLien Users Group Georgia Meeting

On January 21st we held the first meeting of what we are hoping develops into our Georgia Users Group for Premier eTitleLien™. (Our primary Users Group will have its fifth meeting on February 10th in Columbia, SC.) The Users Group President, Dara Biswell of Heritage Trust FCU, and Vice-President, Lisa Vandys of Carolina Foothills FCU, both attended along with several of our Georgia customers.

Prior to the Users Group, we held an information session for prospective customers about our ELT services with an emphasis on how the program works in Georgia. We reviewed a lot of the basics (cost savings, fraud reduction, fewer missed titles) and gave a brief demo of Premier eTitleLien™. We noted our experience working with lenders in the newly mandatory states of Pennsylvania and Louisiana and highlighted the ease of use of working with state ELT programs. Our attempt to demo the Georgia Title Check service didn't work. Live demonstrations are such wonderful things. :(

As part of this information session, and since we had several of our customers there, we offered a chance for them to share how they are using ELT and for anyone else to ask any questions. I was pleasantly surprised (as usually happens) by their praise. Two of our Georgia customers (Citizens Trust Bank and Augusta VAH FCU) also added their reflections about the program. I wish we had recorded it.

Lisa opened the Users Group meeting and Dara spoke about the mission, goals, and structure of the group. Ann Gunning (CIO here at Decision Dynamics, Inc.) gave an update on each state's ELT program, noting progress and goals for each of the states. I briefly (since I had given a full demo earlier) highlighted some changes users can expect in our next release. We also demonstrated the new GA Title Check (working this time!) confirming (with current Georgia titles) both an inactive lien and a lien correctly placed.

We then opened a discussion of support issues, problems, and suggestions.

• A suggestion came up that Premier eTitleLien™ could do a better job of highlighting which state issued the electronic title that was just received.
• I asked if anyone had any trouble with providing proof of lien to other companies. The only problems really seem to come from local entities, like local insurance agents, especially those not in ELT states.
• A desire for an ELT program in Alabama and North Carolina was mentioned.
• A question came up about Texas seeking approval to allow electronic signatures for title applications. We explained what we knew about the Federal regulation and Virginia's experience doing the same thing.
• We also briefly discussed the problem of customers claiming to have a duplicate title or of attempting to forge release documents, and the recent success in those areas due to the states' (SC and GA in this case) policies regarding ELT.
• We also mentioned that the new requirement that each state check incoming out-of-state titles against the NMVTIS database was slowing down the lien recordation process for those titles.

We'd love to have your feedback on any changes you'd like to see with ELT in your state or the Premier eTitleLien™ program.

Image: Oriental Poppies by Georgia O'Keefe

California: DMV Offices Experience Network Outage

As reported by the AP, all the DMV office branches in California were unable to connect to the central computer system, preventing them from processing paperwork. A report by CNET clarified that computers were down for about two hours due to a router glitch.

The CA DMV did the sensible thing and continued to process work from customers by hand until access to the system could be restored.

California's budget struggles have resulted in reduced hours at all DMV offices and the closure of several others. The DMV is encouraging use of their online services and providing the option to schedule appointments up the 45 days ahead of time. Penalties are currently being waived until the next business day for due dates that fall on an "offices closed" Friday.

Other state DMVs are also feeling budget-related strain. Wisconsin has reduced hours at most DMV locations and has scheduled office closings for employee furlough. Louisiana is also considering ways to implement mandatory budget cuts without reducing office locations or hours.

Image: from Portola Redwoods State Park

Georgia ELT's best features

We're heading to Georgia today to host another "Open Forum" and participate with our users at the GA Users Group meeting (both are January 21, 2010 - missed them? Join us for our SC Users Group meeting on February 10, 2010). You can always find our upcoming events at http://etitlelien.com/events.aspx.

Our customers have been participating in the ELT program in Georgia since July 2008. Any state ELT program has significant benefits to lenders, but each state has it's own "specialties". We're working with each state to take their best ideas and get other states to incorporate those as well.

Georgia ELT's best features include:

• Requiring electronic release for electronic titles. This is not unique to Georgia (Florida and Louisiana also require electronic release) but is not a common restriction. This requirement is a significant fraud prevention measure.


• Conversion of Paper Titles to Electronic Titles. Georgia is the simplest program to work with by far, integrating this feature into their standard ELT process.


• *New* The GA DOR has made a title inquiry service available for lenders to inquiry on the status of their liens. This is an excellent research tool for lenders, helping to prevent fraud and reduce inquiries with the Motor Vehicle Division.

As with all other states, signing up to participate with Georgia is free of charge and an excellent way to making managing titles easier.

Image: Thronateeska Heritage Center, GA by Brown's Guides

Is Premier eTitleLien Secure?

One question asked by most customers is about security related to our application. Premier eTitleLien™ is a web-based application developed by lenders for lenders to give them tools to manage their titles by working with each states ELT program. As a web-based application, it is very easy to use and to get started without needing to install software on lender's computers.

Data Security

All data sent using Premier eTitleLien™ is encrypted using SSL. Unencrypted access to our servers is denied. Each lender's data is "stamped" with a DDI assigned code preventing other lenders from accessing their data. Data from each state is retrieved securely and the lender's database is updated with their records.

Access Security

Access to each lender's data is controlled by that lender. Usernames and passwords are assigned, giving (or denying) users rights to see (or makes changes to) data appropriate to them.

Protection From Equipment Failure or Disaster

DDI implements an internal disaster recovery plan that is reviewed each quarter. Our servers are hosted in a secure environment with multiple redundancy.

Reliability of Decision Dynamics, Inc. (DDI)

At the request of our customers, we undergo an annual SAS 70 audit that we are willing to provide to companies that require it. We stay compliant with the Sarbanes Oxley Act and the Gramm-Leach-Bliley Act as well as HIPAA regulations (to meet the requirements for other products not related to ELT).

One bottom line to consider: while DDI fully intends to be absolutely reliable and provide an excellent product and customer support, the ELT program is about having liens on file with the DMV. Your ultimate recourse (for any ELT provider) is to work with the state DMV office to file or release liens.

Image: Map of Glacier Bay National Park, Alaska. (why? hint: pun)

More Questions about ELT in Louisiana

Some additional questions have come up in our discussions with Lousiana lenders (see the previous list).

What's the minimum I need to do to be in compliance with the new law?

Initially:
The law requires that you register with a Louisiana public tag agent. DDI can be your ELT provider (though we are not an LA PTA) because we work with Auto Title Express (our tag agent in Louisiana). You can find all the forms we require at http://www.etitlelien.com.

Ongoing:
1. Verify that electronic liens sent to you are your liens.
2. Release liens once loan is satisfied or request a paper copy of the title for totaled vehicles, repossession, or owner moving to another state.

This "minimum" approach misses most of the benefits of participating in an ELT program, but keeps you in compliance with the law.

What is a PTA?

A public tag agent (PTA) is an agent of the Office of Motor Vehicles that is authorized to do certain transactions as if they were an actual OMV office. In this context, the PTA provides access to the LA OMV ELT program.

What if my customer doesn't receive a title?

When you release a lien, the OMV assumes the responsibility to mail the title to the owner. If they do not receive it, they can request a duplicate copy of the title from the OMV at any time since there is no longer a lien recorded on the title. Furthermore, the OMV will waive the duplicate printing fee for titles more than 30 days overdue but less than 60.

Are boats included in the ELT program?

No. The ELT program applies to anything titled by the OMV. Boats are currently handled by the Louisiana Department of Wildlife and Fisheries.

Do I need a separate code for other states (like Texas)?

Yes. Each state issues their own ELT codes. (Louisiana calls this the "ELT code". It is known by other terms in other states including Customer Number and FIN Number.) Premier eTitleLien™ keeps track of these codes to print on the state title application.

Should I have more than one ELT code?

Usually no. Work can be divided up among employees without needing separate codes. (Two separate codes from the same state really mean two separate installations with their own users, branches, and configurations.) The system is easier to manage with only a single code.

"Our customers are used to getting titles when they pay off a loan" or "I have a customer coming in who wants to meet the vehicle buyer so they can get a title. What do I do?"

First (and I'm not trying to be unkind), your customers must realize that the situation with titles is changing in Louisiana by legislative order. You are required to participate in ELT and that means you no longer store titles at the bank.

Second, when you process a release electronically (which is required), your lien is released. Customers will get a clean title from the OMV and do not need to contact you even if they later lose the title.

Third, if your customer informs you ahead of time that they are coming in to get a title, you can request a paper copy of the title with your lien still on it and have it ready for the customer. That requires advance notice from your customer as it will take a couple days for the postal service to mail the title to you.

Other questions answered on this blog:

How do we handle the costs to participate?
I heard the deadline was June...
Are there any exceptions to who has to participate?

Image: "Oak Alley"

Louisiana: Who is required to participate in ELT?

As we continue meeting with lenders in Louisiana explaining the "new" (not really) now mandatory (really really) electronic liens and titles program, we usually get the same questions (which is why we're explaining). :)

One question I haven't heard that I wanted clarification on was "Who is required to participate in ELT?" or more precisely, "Is anyone allowed to not participate?"

Most of La. R.S. 32:707.2 uses the phrase "bank, finance company, lending institution, or other lender" as in

Each bank, finance company, lending institution, or other lender shall designate a public tag agent with which such bank, finance company, lending institution, or other lender shall interface its computer system for the purpose of receiving electronic confirmation from the department...

The only deviation from this language is

The department is hereby authorized to promulgate rules and regulations in accordance with the Administrative Procedure Act, to provide for certain limited exceptions to the electronic recordation requirements set forth by this Section, for individuals and lienholders that are not normally engaged in the business or practice of financing vehicles. [emphasis mine]

There does not seem to be an exception for certain kinds of lenders, volume of vehicle loans, or for out-of-state lenders. The only exception is for lienholders (individuals or businesses) who are not lenders.

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