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Effective January 1, 2021, 49 CFR 580.17(3) will exempt “a vehicle manufactured in or before the 2010 model year that is transferred at least 10 years after January 1 of the calendar year corresponding to its designated model year”. CFR 580.17(4) will exempt “a vehicle manufactured in or after the 2011 model year that is transferred at least 20 years after January 1 of the calendar year corresponding to its designated model year”.
Federal regulations at 49 CFR Part 580 recently authorized the use of electronic signatures for odometer disclosure statements and specified technical requirements to ensure validity and security of the electronic signature. Because odometer disclosure statements are required and regulated by federal law, the department proposes to adopt practices that conform to those federal electronic signature requirements.
8. Anticipated economic impact of implementing the rule (note if the rule is likely to have a significant economic impact on small businesses):
In 2018, the most recent complete calendar year data available, DMV processed 396,023 title transactions involving vehicle 10 to 20 years old that, under the new Rules, would now require an odometer statement. This accounts for 19% of all title transactions for trucks and autos.
Assumptions:
- 1 odometer statement requires an administrative burden of 1 minute.
- The WI fleet would remain consistent moving forward in regard to size and relative age.
- The administrative burden is reflective of when the Rule is fully implemented in 10 years.
396,023 annual title transaction results in 396,023 minutes or 6,600 hours of administrative burden annually.
According to NHTSA data, 16% of vehicles over 10 years old are sold by motor vehicle dealers. When the Rule is fully implemented, the estimated annual administrative burden for motor vehicle dealers in Wisconsin would be an estimated (6,600 * 16%) 1,056 hours.
The department estimates the use of electronic signatures will save money and expedite vehicle title transactions for those individuals and business that choose to use electronic signatures, for some or all of the signatures required during vehicle title transactions. This rulemaking intends to retain the current use of handwritten signatures and allow--but not require-- the use of electronic signatures, so the department anticipates no increase in costs as result of this rule.
Contact Person:
  Reed McGinn
  Wisconsin Department of Transportation
  Division of Motor Vehicles
  4822 Madison Yards Way, Room 206
  Madison, WI 53705
  (608) 266-7857
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