Enforcement of Title and Registration Requirements
By Erin Palmero
August 25, 2022
Subject Matter Expert: Natalie Beach, Director, Compliance Services
Over the last two years, we have seen an increase in enforcement by states/provinces requiring clients to be able to validate that they are in an active status with relevant jurisdictions to conduct business. In order to fulfill the registration process, companies must be in good standing with their DMV or Secretary of State.
It is critical to have the knowledge of the title, registration and license process and requirements to properly register your vehicles. A 147c/EIN letter or SS4 (issued by the IRS and dated within the last two years) and business license have become standard documents used in the registration process as validation of the business. A misspelled corporate name or simple punctuation error can “red flag” an entire account within the DMV database.
Why Are These Requirements Important?
More jurisdictions are requesting these documents to validate the client’s name, Federal ID, and to confirm that the business is actively registered with the IRS and/or state/provincial level DMVs or MOTs.
Business Name Validation
All companies need a copy of their 147c and/or business license matching the name Wheels Donlen uses on their vehicle registrations. We highly recommend sending the current copy to Wheels Donlen in order to maintain this level of accuracy of our records and to be able to share with the appropriate jurisdictions on an as needed basis.
Business licenses are often county specific and are required for titling based on where vehicles are garaged. These licenses are typically renewed annually, and Wheels Donlen needs these documents to complete the licensing process.
Some specific examples of jurisdictions are:
- Jefferson County, AL
- Cobb County and Fulton County, GA
- Washington, D.C.
We are seeing stricter enforcements that are expanding beyond vehicles, potentially affecting the client’s standing with the state and their entire fleet.
Unemployment Insurance Fund
Maryland, like most states, has set up an unemployment insurance fund to payout benefits. Employers within the state must pay to the Maryland Department of Labor, Licensing and Regulation contributions for the Unemployment Insurance Fund on taxable wages for covered employment that is performed for said employer. An employer must pay contributions at the rate of a statutory percent of the taxable wage base. There is an annual examination of employers to ensure the correct contributions have been made, and that is where the assessed liability emerges.
As a result, the state now has the ability to place a hold on all vehicles of the company registered, until the its unemployment fund has been paid. This very likely could be a precedence for other states to follow.
This is just another example of how jurisdictions affect the registration process. To clear an insurance suspension, the client must work with their broker to file electronically to clear a suspension flag. The most affected states are North Carolina, Pennsylvania and Maryland.
How Wheels Donlen Can Support You
DMV and Secretary of State Registration
To guide you through the DMV/SOS requirements of your vehicle’s compliance, you can download our business registration and licensing tips here.
As states continue to increase their enforcement, we are committed to making our clients as aware as possible of the licensing and registration requirement changes. Through our proactive notifications and your cooperation, we can be on our way to managing your compliant fleet.
If you have any questions or concerns regarding this topic, please feel free to contact us!