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TIADA Advocates for Dealers in TxDMV Rulemaking Process

The Texas Independent Automobile Dealers Association (TIADA) recently submitted formal comments to TxDMV on seven proposed rule changes published in the July 25 Texas Register. Our recommendations emphasize clarity, fairness, and the reduction of unnecessary burdens for independent dealers.

Why It Matters for Dealers: Advocacy at Work

The rulemaking process is where decisions are made that shape your business environment. Part of TIADA's advocacy work is making sure agency decisions reflect the dealer perspective. By submitting formal comments and engaging directly with TxDMV leadership, we represent dealer voices to help keep compliance rules fair, clear, and practical for Texas dealerships.

The Seven Key Comments Submitted by TIADA:

  1. Scrivener's Error (§215.183(k))
Fix an incorrect internal reference so the rule applies as intended.
  1. Temporary Tag References (§215.133(c)(1))
Remove outdated references to July 1, 2025, to prevent confusion and align with the new plate system.
  1. Certificate of Occupancy (§215.133 & §215.140)
Limit requirements to new facilities, relocations, or permitted remodels instead of ongoing renewals.
  1. Conjunction & List Consistency (§215.141, §215.144, §215.155, §215.158)
Standardize formatting to improve readability and consistency.
  1. Dealer Plate Issuance (§215.150)
Revise language from “must” to “may,” giving dealers flexibility in cases of system failure or restrictions.
  1. Minimum Plate Allocations (§215.151)
Establish a minimum allocation of five tags for all plate types. This adjustment would ensure dealers have access to out-of-state plates or buyer's temporary tags for occasional or clustered transactions, supporting uninterrupted service to customers.
  1. Vehicle Transfer Notices (§215.141(b)(28))
Request review of transfer notice rules, since dealers often lack required information when buying at wholesale auctions.
 
Next Steps: September 18 TxDMV Board Meeting 
The final outcome of these proposed rules will be announced at the TxDMV Board Meeting on September 18. TIADA will continue to provide updates and advocate for fair, practical regulations that protect independent dealers across Texas.  


Read TIADA's Full Comment Letter

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