It is important to note that while each state is required to perform a verification check on an out-of-state vehicle before issuing a certificate of title, neither the Anti Car Theft Act nor its implementing regulations require states to change the way they handle vehicle branding or other titling decisions. In the inquiry process, the laws of the new state of title will determine the status of the vehicle (e.g., branding or title type); states are not required to take any action based on data accessed. The information received from NMVTIS should be used to identify inconsistencies, errors, or other issues, so entities and individuals may pursue state procedures and policies for their resolution. Because NMVTIS can prevent many types of fraud beyond simple brand washing, states are encouraged to use NMVTIS whenever possible for verification of all transactions, including in-state title transactions, dealer reassignments, lender and dealer verifications, updates, corrections, and other title transactions.
States are required to report the following data into the system:
- an automobile’s VIN.
- any description of the automobile included on the certificate of title, including all brand information.
- the name of the individual or entity to whom the title certificate was issued.
- information from junk or salvage yard operators, or insurance carriers regarding their acquisition of junk automobiles or salvage automobiles, if this information is collected by the state.
The Anti Car Theft Act also requires the operator of NMVTIS to make available the odometer mileage that is disclosed pursuant to 49 U.S.C. 32705, and any later mileage information, on the date the certificate of title is issued if it is in the state’s title record for that vehicle. Accordingly, the rule requires states to provide such mileage information to NMVTIS.
States shall provide new title information and any updated title information to NMVTIS at least once every twenty-four hours. In addition, with the approval of DOJ, the operator, and the state, the rule will allow the state to provide any other information that is included on a certificate of title or maintained by the state relating to the certificate of title.
Title Verification and Reporting of Data – Two Approaches:
The architecture of NMVTIS was designed with input from the states. Flexibility for states to meet the requirements of the NMVTIS Final Rule has generated the two approaches below (Online Integrated and Batch Data Processing). Some states have developed the batch data processing model approach first and migrated to the online integrated approach, while other states have moved directly to the online integrated approach. The decision appears to be a factor of time, funding, and opportunity. The NMVTIS Final Rule does not stipulate which approach a state must take to meet its requirements.
- Online Integrated
Online integrated is the optimal approach, as it enables the state to truly integrate the NMVTIS application into its titling application, making title verification and reporting of data nearly seamless to the user. The integrated approach is comprehensive and impacts almost all aspects of a state’s titling process. As a result, the integrated approach is typically implemented when a state is planning to modernize its titling application. This approach tends to require more time to develop and implement, as both state and system operator resources must fully understand NMVTIS system requirements and state processes, to ensure they are correctly integrated, and appropriate procedures are put in place. The approach is cost-effective in the long run, as integration of the NMVTIS process into the state titling system reduces the manual processing required with the Batch Data Processing approach (described below). In addition, tight integration of the NMVTIS process into the state titling process provides higher assurance that verifications are done consistently and resulting title updates are done in a timely and accurate fashion.
- Provision of Data: As part of the state onboarding process, states provide to AAMVA extract files that includes their title and brand data. Next, the title and brand data are loaded into NMVTIS. From that point forward, states with fully integrated access to NMVTIS have their title transaction updates sent to NMVTIS in real-time. Additionally, these states receive real-time notifications through NMVTIS when a vehicle from their state is retitled in another compliant state. States can also build the help desk tools required to perform data corrections to their title and brand data in NMVTIS.
- Title Verification: The online integrated approach provides access to NMVTIS central site data (Title, Brand, and JSI) that is maintained by AAMVA, as well as theft data maintained by NICB, and vehicle data maintained on the state’s titling system.
- Batch Data Processing
The batch data processing approach is generally less complex and costly to develop and implement than the online integrated approach since it does not require full integration of a state’s titling applications. However, the batch approach still requires that state and system operator resources fully understand the NMVTIS requirements and state processes to ensure they are correctly integrated, and appropriate procedures are put in place. This is intended to be a short-term approach geared toward states with limited IT resources and allows a state to implement NMVTIS in a relatively brief period. Lack of full online integration between the NMVTIS central site and the state titling system may make this approach more prone to data entry errors and may increase the time at the counter to process manual inquiries. The increase in processing time translates into increased operating costs.
- Provision of Data: States provide initial batch files of their title and brand data to AAMVA to load into NMVTIS. After the initial load, states provide daily update files to keep data current. The batch files are transmitted to AAMVA via a Secure File Transfer Protocol.
- Title Verification: AAMVA provides three solutions for batch states to perform title verification: 1) State Web Interface (SWI); 2) State Batch Inquiry (SBI); 3) or a partial online integrated approach that uses the online inquiry transactions. SWI allows a state to conduct a single VIN inquiry into NMVTIS and the response includes data from NMVTIS central files (VIN Pointer, Brand, and JSI), theft data, and detailed state vehicle data. SBI allows a state to submit a file of VINs to NMVTIS and the response includes data from NMVTIS central files (VIN Pointer, Brand, and JSI). The state can also utilize the online inquiry transactions to perform title verification.