The Pennsylvania Automotive Association reports the Pennsylvania Department of Transportation (PennDOT) is visiting dealers across the Commonwealth to insure paperwork is properly organized and stored and training has occurred as required. Sometimes, there are discrepancies between the dealership’s understanding of the requirements and what is being communicated to them by the auditor. Dealers are encouraged to contact PAA if questions arise during the audit process.

The following items are the most common deficiencies found by PennDOT.
• Files Are Not Properly Organized. If a registration plate was issued, agent copies must be filed separately from other
registration transactions (i.e., transfer of plates and issuance of intransit plates) and in consecutive order by plate number issued. If a temporary registration card only (transfer of plate) was issued, agent copies must be filed in chronological order by date of issuance.

• Temporary Registration Permits (Window Permits) Are Not Retained Properly. The top portion of the temporary registration permits are to be retained in the booklet and are not to be separated and placed in the files. Dealers must have stand alone files and retain them for three years.

• Yellow Copies of the Application or Applicant Summary Without Copies of Supporting Documents. Agents are required to retain copies of the front and back of all supporting documents related to the title transfer. In many cases, only front copies are being retained. This includes the acceptable Pennsylvania identification credentials. In addition, the applicant summary sheets are not being completed prior to filing. All forms must be
completed in their entirety.

• Incomplete Paperwork. Motor vehicle forms are not being completed in their entirety. Forms must be completed fully. This includes the agents DIN as well as the customer’s driver’s license or identification number being listed in the appropriate space.

• Employee Training. Agent service contracts require all new employees engaged in the agent service to attend an approved Title and Registration Training Course prior to being added to the contract and completing PennDOT paperwork. The contract also requires a refresher training course (Advanced Agent Service Training Course) at least once every two years.

• Affidavits not Being Completed. The contractor must, at the time of hiring and annually thereafter, secure an affidavit from each person involved in providing the agent service that the person has read and understood the provisions of 75 Pa.C.S. Chapters 11 (relating to certificate of title and security interests), 13 (relating to registration of vehicles), 23 (relating to motor vehicle transaction recovery fund), § 6114 (relating to limitation on sale, publication and disclosure of records), 75 (relating to authorization of agent and messenger services) and 67 Pa. Code, Chapter 43 (relating to temporary cards and plates) and is required to retain the statement(s) on file for inspection upon request by
PennDOT. Copies of vehicle code sections should be available at the dealership.

• Unauthorized Personnel at Locations. PennDOT’s contract information must be updated when employees leave a business or when a business gains additional employees. When new employees are hired, employers must supply the new employee’s name and job description, along with a current criminal history check, educational certificate and copy of a valid ID to PennDOT.

When an employee leaves the business, employers are required to notify PennDOT that the employee is no longer authorized to operate under their contract. Employee updates should be made through the DAS system. Adding an employee requires the agent to fill out Form MV-73B, “Messenger and/or Agent Service Employee Report for PennDOT.”

• Criminal History Check. PennDOT requires that all employees listed on the PennDOT contract have updated criminal history checks annually and retain them on file for inspection by PennDOT annually.

• Acceptance of Non-PA Driver’s License or ID, Fraudulent ID or No ID Being Used to Complete Paperwork. Only the identification documents listed on the Acceptable Identification Documents to Complete Motor Vehicle Applications Fact Sheet are acceptable for an agent to use to title and/or register a vehicle in Pennsylvania. The front and back of the identification document being submitted must be reviewed. Copies of the front and back of the purchaser’s acceptable identification document must be attached to all title and registration documents submitted to PennDOT whether submitted manually or online. Driver’s Licence Data Verification (DLDV) should be performed when required.

• Vehicle Identification Number (VIN) Verifications Not Being Performed. Section 1103(e) of the Pennsylvania Vehicle Code requires VINs to be verified in conjunction with an application for certificate of title. Verification shall be required when: 1.) A Pennsylvania resident acquires a new or used vehicle from a nonresident for use in this Commonwealth. 2.) A nonresident brings into the Commonwealth, in connection with establishing a Pennsylvania residence, a vehicle previously titled or registered in another state or country. 3.) The application for initial certificate of title is for a truck, truck-tractor, or motor home, regardless of source of ownership.

• Paperwork Not Submitted in Required Timeframes. The following timeframes are required for paperwork submission to PennDOT:

1.) Agents must submit paperwork within 20 days.

2.) Messengers must submit paperwork within five days.

3.) An agent who is also a messenger must submit paperwork within five days.

4.) Online in transit transactions must be submitted within five days. Reminder: Online agents must also submit paperwork to their integrator.