Customer Convenience Can Cut Into Compliance


In our December 2009 newsletter we discussed some potential perils of conducting vehicle sales with customers at their homes. In addition to worrying about the customer getting a statutory three day right to rescission and making sure that proper notices are provided to customers, dealers engaged in sales with customers located off of the dealership premises also need to be concerned with the other agencies regulating them, namely PennDOT, the Vehicle Dealer Board and the Department of Banking.


PennDOT regulates a dealership’s ability to issue registration plates and process registration and title transfers for customers. The way this is done has changed drastically in the past ten to 15 years. Most dealerships are now connected electronically to PennDOT to process registrations and title transfers in real time allowing customers to leave a dealership with their permanent credentials (or to receive them several days later in the mail). In addition to customer convenience, being able to process PennDOT paperwork also provides dealers with an additional revenue source.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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