Since the beginning of summer there have been some changes to the VIN verification form, REG 31, and the issuance of MEMO VIN 2017-08 that have caused a lot of confusion among the DMV, the CHP and private VIN verifiers like myself. It is my opinion that the flood of military vehicles that came into California had caused the DMV & the CHP to revise procedures, forms and issue memos to revise how these vehicles were being verified & registered. This, in my opinion, brought other vehicles into the attention of the CHP & DMV: pre-1970 vehicles. The MEMO VIN 2017-08 states "only the California Highway Patrol (CHP) may search for an alternative vehicle identification number (VIN) and complete the Verification of Vehicle (REG 31) form when the U.S. Federal Certification Label is missing, illegible, or damaged." Well, pre-1970 vehicles did not have this label, so therefore, this memo brings our old Chevys and Fords and Pontiacs into the scope of what this memo was referring to. However, a month later or so, the VIN verification form, the REG 31 form, was revised. The form has a box that you could check where it asked for the Federal label, and if it were pre-1970, it did NOT apply, so you checked the box that said "pre-1970". The form itself leads one to believe that we can now verify pre-1970 vehicles again, because it acknowledges that these vehicles did not have the federal label to begin with, so it would remove these vehicles out of the scope of MEMO VIN 2017-08, and therefore, it would not apply to them. However, according to the DMV, that is NOT the case. What is happening right now is that several of the transactions we have processed, and other transactions that others have processed, are being kicked back and are requesting that the VIN verification be re-done by the CHP. Because there has been no memo to address this issue, MEMO VIN 2017-08 still stands.
We, as VIN verifiers and registration services, are getting contradictory and confusing information from DMV techs, DMV managers and CHP verifiers. As of right now, we are still able to verify these older vehicles apparently, however, that could change at any time. This situation is getting out of hand because CHP appointments are so far out, we are talking about a 2 to 3 month wait for an appointment. However, with the flood of these older cars that the DMV and private VIN verifiers could verify before, you could see appoinments out as far as 6 to 8 months (I am not exagerating). The decision that needs to be made will have such a negative economic impact on private VIN verifiers like myself, a negative impact on the work flow of the CHP and DMV, that it is a situation that must be fixed sooner than later.