AFSA has recently issued a response to the New York Department of Motor Vehicles concerning new guidelines for electronic lien and lease reporting. In its letter, AFSA raised issues with the proposal, which would require lenders and lessors to use a specific third-party vendor for electronic reporting.
AFSA stated that the mandate could impose additional burdens, increase costs, and slow down the processing of vehicle titles. The concern is that this requirement could disrupt established practices between lenders and the DMV. AFSA highlighted, "AFSA members already work directly with the DMV to ensure accurate and timely lien and lease recording."
The organization also noted that the proposal may not accommodate the needs of national lenders and suggested it may impact access to vehicle financing within New York. AFSA has called for a revision, suggesting the DMV provide options for direct reporting or allow a choice of approved vendors, similar to what is practiced in other states.
The full correspondence and other related letters are available on AFSA's website in the direct advocacy section.