nmvtis webinar 022813 (final) 2

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

ISO ClaimSearch® NMVTIS Reporting RequirementsWeb Seminar – February 28, 2013

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

Welcome!

2

Presenters

Todd Brighton NMVTIS Enforcement Coordinator, Bureau of Justice Assistance

Carlos Martins Assistant Vice President, ISO ClaimSearch

Barbara Beninati Manager, Subscriber Services

Kristi Griffith ISO ClaimSearch Training Analyst

Webinar Objective Statement: Following today’s webinar, attendees will have a clear understanding of the NMVTIS program and what steps

they will need to take to ensure their company is in compliance.

3M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS ReportingToday’s Agenda

Who … Topic …

Todd Brighton, BJA • Program History, Goals, Key Stakeholders

• Reporting Requirements• NMVTIS Enforcement Summary• FAQs• Promising Practices• NMVTIS Resources

Carlos Martins, ISO • NMVTIS Outreach Program

Barbara Beninati, ISO • Reporting “Best Practices”

Kristi Griffith, ISO • Demo – Web Reports

All • Questions

4

NMVTIS Program History, Goals,

and Key Stakeholders

National Motor Vehicle Title Information System (NMVTIS)

NMVTIS was established by the Anti Car Theft Act of 1992 (Public Law 102-519), the Anti-Car Theft Improvements Act of 1996 (Public Law 104-152), and its implementing regulations (28 C.F.R. part 25).

NMVTIS was created to:• Prevent the introduction or reintroduction of stolen motor vehicles into interstate commerce

• Protect states, consumers (both individual and commercial), and other entities from fraud

• Reduce the use of stolen vehicles for illicit purposes including funding of criminal enterprises

• Provide consumer protection from unsafe vehicles

5

NMVTIS Key Stakeholders

• U.S. Department of Justice (DOJ)

• NMVTIS Federal Advisory Committee

• American Association of Motor Vehicle Administrators (AAMVA)

• Data Consolidators

• States

• Consumers

• Junk Yards, Salvage Yards, Insurance Carriers

• Law Enforcement

6

What Are the NMVTIS Reporting Requirements

for Insurance Carriers?Insurance carriers are required to provide information on all automobiles of the current model year or any of the four prior model years that the carrier, during the prior month, has obtained possession of and has decided are junk automobiles or salvage automobiles (including automobiles determined to be total loss):

• The name, address, and contact information for the reporting entity (insurance carrier)

• Vehicle Identification Number (VIN)

• Date on which the automobile was obtained or designated as a junk or salvage automobile (including those determined to be a total loss)

• Name of the individual or entity from whom the automobile was obtained (owner name or lien-holder name)

• Who possessed the automobile when it was designated a junk or salvage automobile

• Name of the owner of the automobile at the time of the filing of the report with NMVTIS

(either the insurance company or the owner, if owner-retained)

7

Although not specifically required by the Anti-Car Theft Act, the Department of Justice strongly encourages insurance carriers to:

• Include the primary reason for the insurance carrier's designation of salvage or total loss in this reporting

• Provide the NMVTIS operator with information on other motor vehicles, including older model automobiles, and other information relevant to a motor vehicle's title, including the disposition of such automobiles, and the name of the individual or entity that takes possession of the vehicle

The reporting of this information by insurance carriers may help reduce VIN cloning and assist in preventing and eliminating fraud.

8

9

NMVTIS Enforcement Summary

Are There Penalties for Businesses

That Do Not Report As Required?

• The NMVTIS statute includes an enforcement provision authorizing DOJ to impose and collect penalties for those junk yards, salvage yards, and insurance carriers that fail to meet their reporting obligations pursuant to the Anti Car Theft Act as amended.

• BJA’s enforcement efforts are focused on the reporting period from April 2009 to the present.

• Failure to report to NMVTIS as required is punishable by a civil penalty of $1,000 per violation. Accordingly, for example, a failure to report 100 junk or salvage automobiles could result in a civil penalty of up to $100,000.

10

11

NMVTIS Enforcement Summary

Outreach

• National associations

• DOJ nationwide direct mailings

Enforcement

• Coordination

• Site visits

• “Referral” process - NMVTIS website mailbox nmvtis@usdoj.gov allows the public to inform BJA of non-reporting entities

• Office-based monitoring

Question: Has BJA identified any examples of non-compliance? If so, what corrective actions were taken?• BJA has identified examples of non-compliance. We work with the reporting entity to obtain voluntary compliance. 

• Referral, Site Visit, or Office-Based Review

• Nonreporting Warning Letter

• Notice of Civil Penalty Letter

• BJA Director Determination

• BJA has issued nine (9) Notice of Penalty letters to businesses in California, Florida, New Jersey, New Mexico, Ohio, and Pennsylvania.  The number of nonreporting violations range from approximately 150 to 2,800 vehicles and thus could result in penalties ranging from $150,000 to $2,800,000.

[Note – A copy of the Final Penalty Decision Considerations document is available on the NMVTIS website. BJA uses these considerations when determining a penalty for nonreporting.]

12

13

NMVTIS FAQs

Question: Is there an amendment or correction process for NMVTIS records submitted in error?

Answer:   Yes. Each of the reporting services offers a process for making amendments or corrections to NMVTIS reports. Detailed information regarding amending or correcting a record after it has been submitted to NMVTIS may be obtained by contacting the data consolidator that accepted the record. A list of the NMVTIS data consolidators is available at: www.vehiclehistory.gov/nmvtis_auto.html.

14

Question: How does one determine to whom the junk automobile or salvage automobile was provided or transferred? Does the entity to which the automobile is transferred or provided need to be named on the title in order for that entity to have an NMVTIS reporting obligation?

Answer: Under the NMVTIS regulations, to whom the junk automobile or salvage automobile was provided or transferred should not be understood to be limited to the provision or transfer of a title for such automobile. For example, if an insurance carrier transfers or provides a junk automobile or salvage automobile to a salvage auction, then the insurance carrier should identify the salvage auction in the “to whom the automobile was provided or transferred” data field of the applicable NMVTIS report. That the salvage auction’s name does not appear on the title for the applicable automobile, provides no basis for the salvage auction’s name to not appear on the insurance carrier’s report, nor does it provide a basis for the salvage auction itself to be exempt from also reporting. Local, state, and federal law enforcement agencies rely on NMVTIS to obtain cumulative vehicle histories and establish a vehicle’s chain of custody.

15

Question: If an insurance carrier determines a vehicle to be salvage or total loss, but does not pay a claim (e.g., third party claims) is the insurance carrier required to report the determination to NMVTIS?

Answer: Yes, an insurance carrier determination of salvage or total loss, regardless of whether a claim is paid or not, must be reported to NMVTIS.

16

Question: My company is a salvage pool. Can we report to NMVTIS on behalf of our insurance company customers?

Answer: Every insurance carrier, and junk and salvage yard is required to report to NMVTIS. Insurance carriers may arrange to have the reports provided by another entity to satisfy its reporting obligation if those other reports are filed in a timely manner and contain all of the information that the insurance carrier itself is legally obligated to report to NMVTIS. Although another entity may provide the report on behalf of the insurance carrier, it is the insurance carrier itself that has the legal responsibility for all reporting requirements, including the content and the timeliness of the report. Any report filed on behalf of an insurance carrier by another entity must use the unique reporting ID of the insurance carrier on whose behalf the report is filed.

17

NMVTIS Reporting – Insurance Carrier Promising Practices

• Carriers may want to designate a point of contact within the company to oversee/monitor ongoing NMVTIS reporting responsibilities, as well as, serve as a point of contact for BJA’s Enforcement Program.

• Utilize ISO’s online management reports to monitor your company’s reporting patterns and problem solve potential issues before they become a NMVTIS nonreporting violation.

18

19

NMVTIS Resources

Comprehensive information, FAQs, policy guidance, etc. available at: www.vehiclehistory.gov

For general NMVTIS questions or to make a non-reporting referral, please go to the NMVTIS website mailbox: nmvtis@usdoj.gov

Contact: Todd BrightonNMVTIS Enforcement CoordinatorBureau of Justice AssistanceTodd.Brighton@usdoj.gov

20

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

NMVTIS – Training Outreach Program

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is strictly prohibited.

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS – Training Outreach Program

21

• Background: ISO serves as a NMVTIS data consolidator, representing over 1,500 insurers, recyclers, junk & salvage yards.

• In an effort to support our customers with their NMVTIS compliance, ISO has developed an aggressive new training program with reference tools for Insurers.

• This support campaign was launched in January and will run through June 2013.

• Program purpose: Reinforce compliance rules & requirements Reinforce existing management reports Introduce new “tools” to aid compliance Provide transparency & visibility…

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

22

Program features: Email blasts to members (3) training webinars Social media posts New “Best Practices” Tool New “JOB AID” Tool New “FAQ” Tool Management reports training Trade show / conference

Messaging exposure End-user surveys Random audits

NMVTIS – Training Outreach Program (Con’t)

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is strictly prohibited.

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

23

ISO Next Steps:

• Develop a similar program for our auto recyclers, junk & salvage yard customers…

• Develop a new “self-audit” Program for our customers…

• Develop a new management information “dashboard” for our customers …

NMVTIS – Training Outreach Program (Con’t)

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is strictly prohibited.

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

24

ISO Recommended “Best Practices”

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS ReportingISO Recommended “Best Practices”

25

ISO ClaimSearch reporting: Ensure your company is actively working “rejected” ISO claim reports; only “accepted” claims are processed for NMVTIS reporting!

Required Data: Report the following minimum required fields:1. Policy type2. Parties to loss (i.e. insured, claimant, owner)3. Date of loss4. Coverage and loss type5. VIN (must pass VIN edit)6. Disposition = Total loss ( Important note: This is the trigger that

initiates reporting)

Note: For web reporters: on General Vehicle Information screen, change Vehicle Disposition field to “Total Loss” Note: For System-to-system reporters: Enter “T” in the Disposition field (347 on the UV01)

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS ReportingISO Recommended “Best Practices” (con’t)

26

Required vehicles types: Report all automobiles (defined as vehicles with four (4) wheels, under 10,000 lbs. for road use) including:– Passenger cars– Trucks & light trucks– Multipurpose vehicles (includes SUVs, minivans, etc…)– Current model year + four previous model year cars

Note: ISO will also apply “filters” and perform data quality checks to ensure your compliance.

Optional data: If you selected to submit the optional data the following fields will also be submitted to NMVTIS:

1. Vehicle make2. Vehicle model3. Vehicle model year4. Vehicle style5. Odometer reading6. Vehicles other than automobiles (under 10,000 lbs licensed for road use)

7. Cause of loss

27M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS ReportingISO Recommended “Best Practices” (con’t)

Regression testing: Perform regularly scheduled QA regression testing on your NMVTIS data submissions to ensure total losses are being reported correctly (to ISO). Focus on testing:– Claims identified as a total loss during FNOL– Claims identified as a total loss after FNOL– Claims incorrectly identified as a total loss, and later classified as NO

LONGER a total loss

Balancing & control environment: Monitor your daily claim reporting submissions to ISO ClaimSearch to ensure data quality. Consider creating an “automated” balance & control environment to ensure all claims are being received and processed each day.

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

NMVTIS ReportingISO Recommended “Best Practices” (con’t)

28

Amendment processing: If/when a vehicle is incorrectly transmitted to ISO as a total loss, please send an email to the following address requesting that ISO manually amend the record: ClaimSearchNMVTIS@iso.com

Note: All amendment requests must include: Reporting code, claim number, date of loss, VIN and reason for amend.

Third party administrators (TPAs): Remember to report all total losses you process on behalf of an Insurer under the Insurer’s code.

30 day hold period: Note that ISO is holding all of your total loss reports for 30 days prior to being submitted to NMVTIS.

Management reports: Lastly, and most importantly be sure to review and use your NMVTIS web reports to ensure compliance! NOW ON TO A DEMO …

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

29

Demo – NMVTIS Web Management Reporting

M E A S U R E , M A N A G E , & R E D U C E R I S KSM

© ISO/Verisk 2013. Material contained on these slides is proprietary and confidential . Reproduction or distribution without permission is

strictly prohibited.

Thank You!

30

• To view a copy of this webinar presentation and obtain copies of our new:

“Best Practices” Tool“JOB AID” Tool“FAQ” Tool

visit us at: https://claimsearch.iso.com/ and go to “User Manuals and Guides”

• Please send your questions for NMVTIS to :– ClaimSearchNMVTIS@iso.com or call us at 800-888-4476– For training please send your requests to: info.ClaimSearch@ISO.com