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Auto Recycling Manifesto
Comprehensive Vehicle Branding and Total Loss
Best Practices Guide
7) States should designate clear titling administrative
and oversight authority to cover all regulated enti-
ties and ensure the relevant agency has the au-
thority to make and implement recommended best
practices.
Iowa DOT fills this role.
8) To avoid title washing, states should include a
brand carry-forward provision in their rules.
9) States should require in-state title paperwork be-
fore allowing the sale of vehicles by salvage auc-
tions. The resale of clean title cars from other
states at salvage auctions has been banned by
some states because it enables parties to circum-
vent mandatory branding under rules in the title
states and allows vehicles to be resold under pre-
vious clean titles without regulation.
10) NMVTIS reporting violations should also be a vio-
lation of state law and states should require re-
porting on an accelerated timeframe. These states
should define penalties for violation of non-
registration and reporting under state law. A)
States should also consider requiring salvage auc-
tions to ensure that all buyers/brokers are regis-
tered with NMVTIS before being allowed to pur-
chase at their auctions; B) Towing companies ob-
taining Certificates of Destruction or junking certifi-
cates should be mandated by enforcement au-
thorities to show proof that all such vehicles have
been reported into NMVTIS.
#1 Priority for IAR
11) States must clearly define when title transfer oc-
curs and title branding is therefore required. A)
Violations of the federal Odometer Act should also
be considered violations of state law; B) States
should consider requiring that odometer declara-
tions be provided for vehicles older than 10 model
years old given that the average age of vehicles
on the roads today is over 11 years.
Done in Iowa.
12) Multiple title transfers on a single document
should be prohibited. The transfer under a clean
title of a damaged vehicle is a significant source of
title branding avoidance and a great risk to subse-
quent buyers. A) Any title transfer of a damaged/
total-loss vehicle under a clean title should be pro-
hibited in any case where the vehicle would be
subject to a change in title branding status if the
transfer were being reported. The owner must be
required to get the title branded before being al-
lowed to resell or transfer the vehicle either di-
rectly or through an agent.
Private sales need this
provision in IA.
13) States should prohibit the sale of vehicles on bills
of sale and require all sales of vehicles to be ac-
companied by a state-issued document such as a
certificate of title, a salvage certificate of title or a
certificate of destruction. When sales are con-
ducted in the absence of state-issued documents,
unscrupulous buyers can use bills of sale to obtain
a duplicate title, which will likely be a clean title
from the previous owner because transfer and
branding information has not been reported to the
state. Iowa
Abandoned Vehicle Inspection
14) Salvage title vehicles should require full theft and
safety inspections before being eligible for receiv-
ing a rebuilt/rebuilt salvage title.
Theft Exam in IA.
15) There should be clear definitions of the terms
agent/broker/dealer, and should be required to be
included in any title chain of history.
16) States should close the gap on sales tax avoid-
ance by requiring salvage vehicle sales to be pre-
sumed as sales at retail (and not for resale)
unless the buyer presents a resale certificate as a
licensed automobile dealer, dismantler, automo-
tive repairer or scrap metal processor.
#2 Priority
17) States should require a warning sticker on any
vehicle offered for sale that has been reported as
a total loss by an insurance company or has been
reported as acquired by a NMVTIS junk/salvage/
insurance (J/S/I) reporting entity, or if the certifi-
cate of title contains a brand.
#3 Priority for IAR
18) States should not allow salvage auctions to sell
directly to consumers. A) If a state is contemplat-
ing allowing auctions or wholesalers to sell directly
to consumers they must institute important con-
sumer protections.
#4 Priority (but complex issue)
19) E-titling will be an effective tool in reducing many
types of vehicle fraud commonly committed upon
the public, but states must ensure that state laws
do not conflict with the reporting requirements of
the federal Odometer Act.
Electronic lien release
will roll out before e-titling in Iowa.
20) States must pair all title reporting with reporting
the current title brand when recording that infor-
mation into NMVTIS.
Recyclers News Press
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