Odometer Disclosure Exemption? Not So Fast...

The odometer disclosure exemption changed just over a year ago, on January 1, 2021. The new requirements have affected a significant number of previously exempted vehicles across Texas. In 2021, we reached out to the Texas Department of Motor Vehicles to help answer key questions dealers are asking regarding this regulatory change issued by the National Highway Traffic Safety Administration and what actions dealers should be prepared to take. TxDMV provided the following to help TIADA members:

New Federal Regulations: Odometer Disclosure Exemption Change and Additional Use of the Power of Attorney for Transfer of Ownership to a Motor Vehicle (Form VTR-271-A)

Clint Thompson
Texas Department of Motor Vehicles
Vehicle Titles and Registration Division
The Texas Department of Motor Vehicles (TxDMV) distributed Registration and Title Bulletin (RTB) #013-20 and provided webinars to communicate federal changes to the model year exemption for odometer disclosure from 10 to 20 years and additional uses of the Form VTR-271-A.  The RTB and webinar recording can be found on the TxDMV website.

Effective January 1, 2021, the new 20-year exemption for odometer disclosure applies to 2011 and newer model-year vehicles.  This means a 2011 model year vehicle will not become exempt from odometer disclosure until the vehicle is 20 years old, which will be January 1, 2031.  You will need to ensure that 2011 and newer model-year vehicles have a properly completed odometer disclosure statement. 

TxDMV is aware that not all states implemented the 20-year exemption on January 1, 2021. If you purchase a 2011 model year vehicle and the out-of-state title was issued as exempt, the vehicle will be titled in Texas with the odometer brand as Not Actual Mileage. You should inform any potential buyer prior to selling the vehicle. You will record the mileage at the time of sale and indicate the odometer reading is Not Actual Mileage.    

New federal regulations also include additional permitted uses of the Form VTR-271-A. Form VTR-271-A can now be used when the vehicle is subject to odometer disclosure and the title is lost, held by a lienholder (whether the title is paper or electronic), or an electronic title that cannot be accessed. Use of the Form VTR-271-A with electronic titles includes an electronic title when the lienholder has not released the lien or when the owner on record has an electronic title without a lien. 

There are no changes to how Form VTR-271-A is completed. If the vehicle is subject to odometer disclosure and a permitted use applies, Part A is completed when the motor vehicle is traded in. If you transfer the motor vehicle and a permitted use still applies, then you will complete Parts B and C.

Form VTR-271-A has been revised to accommodate the federal changes, and the revised version will become available once current inventory has been depleted. Your current inventory remains valid for use even after January 1, 2021. 

Required Forms

Required forms can be accessed on the TxDMV website. For questions, dealers are encouraged to contact their local Regional Service Center.

The policy and procedure outlined by the TxDMV are in response to a final rule issued in 2019 by the National Highway Traffic Safety Administration (NHTSA) under the United States Code of Federal Regulations, Title 49, Part 580.


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