Form Update
Form: 735-271 – Abandoned Vehicle Certificate
Link: https://www.oregon.gov/odot/Forms/DMV/271fill.pdf
Form was updated March 1, 2024, all tows prior to March 1 can use previous version of form. However, all tows after March 1 must use the updated form. Please plan accordingly to ensure that you are within compliance with this update and requirements.
Decline in Transporter Renewals
Business Licensing has seen a decline in transporter renewals. 14 in 2024 compared to the 31 last year. Decrease is attributed to the new law restricting transporters to 10 PLATES and prohibiting the usage of these plates outside of Oregon.
Out-of-State Appraiser Increase
Due to Oregon not requiring a mandated bond for Appraisers, applicants are utilizing an Oregon Appraiser Certificate for out of state admission. Due to this potential issue DMV is contemplating a proposal to confine certified appraiser to abandoned vehicle appraisals, reverting back to the way things were prior to the 2009 law change.
** CRITICAL ** Proposed Error Rate Enforcement
Oregon DMV claims that their teams are required to maintain an error rate on all submitted paperwork under 10%, this rate is required after the almost 18-month training onboarding that DMV puts all of their processors through. While this number has not been proven to dealers, they propose that all dealers, regardless of time in seat are to be required to meet or exceed the same standard. This change WILL include fee errors as well as errors caused by changes to forms and policies, regardless of notice.
Failure to meet this standard would result in sanctions, including the revocation of DMV Agent status, thus removing dealers’ ability to process any DMV paperwork without visiting a local branch.
This is extremely problematic, and OVDA has already notified the DMV of numerous issues with this potential policy change. The change is questionable additionally because if dealers lose agent status and must send customers, or they themselves must visit DMV branches, it could increase the workload at strained offices. A problem already plaguing dealers since all documents must be mailed or filed digitally instead of presented and processed at local offices.
Note that for dealers who process 10 or less transactions per month 1 (one) transaction would drop the overall error rate for that dealer under this sanctionable 10% margin.
A second amendment to this change would allow dealers to perform VIN inspections on vehicles outside of their inventory, however, a move to “provide a service to other dealers”. However, dealers would not be allowed to charge for these services.
At the Rules Advisory Committee (RAC) meeting, OVDA’s lobbyist Darrell Fuller provided DMV with a lengthy and detailed written analysis of the new draft rules, pointing out both concerns and objections. We are now waiting for DMV to provide an updated draft based on our input. The formal rule making process has not started on these rules. We will make sure every OVDA member has had the opportunity to contact DMV with concerns about any rules which will cause an unnecessary burden on dealers working hard to do comply with the rules.
On a very positive note, DMV is currently working on a system to allow for fee errors to be addressed online to speed up processing payments. On your behalf, OVDA has been working with DMV on this system since the beginning of 2023, and it is great to see it coming soon. Additionally, we continue to have productive conversations with DMV about providing dealers with additional access to DMV field offices, on a limited basis, when paperwork simply can’t wait for ordinary processing. See the next update for more information.
Transaction Updates
DMV states that dealers are allowed to inquire as to the status of their transactions (started April 22nd, 2024) and submit expedited transactions from 8 AM to 3 PM at the DMV Headquarters lobby. This service mirrors that which was initiated in SE Portland in March 2024. Dealers can utilize smart lockers at DMV Headquarters and the SE Portland Dealer Center for drop-off and pickup of paperwork, receiving a notification when their documents are ready for retrieval.
The turnaround time for mailed-in transactions at DMV Headquarters has consistently remained below 30 days for the past 2 to 3 months, currently standing at approximately 20 days.
If counter service at SE Portland and Headquarters proves successful, Oregon Dealer Services will aim to extend these services to all dealer centers. Counter service at the SE Portland location is restricted to Tuesdays through Thursdays because of ongoing staff training.
Regarding the possibility of lockers in all field offices, there were acknowledged efforts to expand services at all locations. However, space constraints may pose challenges to installing lockers in every field office.
The idea of lockers at all the field offices has been discussed, however, because of space constraints this may be a challenge making this less likely.
These latest proposed changes, and the ratcheting up of pressure on dealers to comply with seemingly arbitrary requirements with little to no flexibility, all in the name of supporting staff, and making their jobs easier, and to increase productivity ignores that ultimately DMV supports dealers and citizens, not the other way around. OVDA has been in the muck fighting to ensure that our industry remains not only viable but profitable, and yet dealers time and again sit on the sidelines waiting to see what happens instead of taking action and joining in the fight against the problematic policies that could in fact ruin their business. Stop Waiting! Stop Watching! Unite with us today and join the fight! Protect your dealership today by joining OVDA. The larger our membership, the stronger our voice!