CUNA supports basic uniform standards to facilitate the electronic disclosure of odometer information both within and among the states, but asked for a lower-level of required authentication. In a letter sent this week, CUNA responded to the National Highway Traffic Safety Administration (NHTSA) and Department of Transportation proposed rule on odometer disclosure requirements that would allow the 50 states to adopt schemes for electronic odometer disclosure statements.
“Our member institutions are frequently involved in the financing of automobiles and the transfer of a title, and the ability to perfect a lien is of utmost importance to our members,” reads CUNA’s letter.
CUNA believes that the current proposal requires a too-high level of authentication. It requires a Level 3 authentication to ensure that electronic odometer disclosure requirements can be electronically signed in person and remotely.
“A Level 2 authentication for electronic odometer disclosures is more appropriate. State departments of motor vehicles (DMVs) often do not support the needed systems to perform the necessary validations required by a Level 3 standard,” the letter reads. “Level 2 standards will facilitate electronic disclosure transactions for those individuals who may not have the necessary established credit or utility accounts to otherwise perform an electronic disclosure.”
CUNA also urged the NHTSA to allow the electronic odometer system to provide a means of electronically sharing the odometer reading with a lienholder or finance company that has an interest in the transaction. This is currently provided by a dealership at the time of purchase.
Within the proposal, CUNA also supports: