This is my opinion on what triggered the major revisions of the REG 31 form. The form – generally speaking, dictates what is needed to be documented. However, the memos below also dictate on what and when things are documented. So the history, in my opinion, on what triggered all of this: a few years back, IronPlanet was selling a lot of decommissioned military Humvees to the public. These Humvees had 6 digit VINs, were “exempt” from emissions, had no Federal Labels, and basically didn’t meet some of the most basic requirements to be registered in California. However, because NO rules were in place at the time before the flood of these Humvees came, many Humvees (i did like 30 myself) were registered as regular vehicles. The DMV and CHP notice this influx of vehicles that should NOT be registered as on-highway and put in place a new version of the REG31 form that immediately made the registration of these vehicles for on-highway use a slim possibility. This new form dictated that if the vehicle does NOT have a federal safety label that ONLY the CHP can do the VIN verification. Remember, the rule is if the vehicle is a post 1979 vehicle, the VIN should be at least 17 digits, and these vehicles should have a federal label. It was setup in such a way that it forced all of these Humvees to be inspected by the CHP. You could still register them, however, for off high-way use ONLY. The issue with all of this was, that because other non-Humvee vehicles (the vehicles the DMV and CHP wanted to catch and prevent from being titled and registered incorrectly) it also put other vehicles, who normally had no issues with VIN verifications or registration, into the same category as a Humvee. What happened was a 1954 Chevy Bel-Air that normally someone like me could verify, was now only verifiable by the DMV or CHP ONLY. This created a massive backlog for the CHP and massive delays for registering vehicles @ the DMV. I want repeat, this is MY opinion, because i do not have a source within the DMV or CHP that can verify what the exact reason was, I formulate this educated opinion.

1. VIN memo 2018-11 – this memo clarifies certain procedures for VIN verifiers. It mostly clarified the rules dictating the documentation of the emissions label. Where before it was understood that we HAD to document the engine family number, this label clarifies that rule on what triggers the requirement to document the label. (PRO-TIP – ALWAYS DOCUMENT THE ENGINE FAMILY NUMBER – GUESS WHAT, EVEN SOME DMV TECHS DON’T NKOW ABOUT THIS MEMO)
2. VIN memo 2017-29 – this memo seemed to have softened the new rules dictated in memo 2017-08. 
3. VIN memo 2017-08 – this memo caused the most confusion – a new VIN verification form version was issued – in conjunction with the form and this memo – many DMV managers interpreted it in a way that prevented private VIN verifiers like us from preventing VIN verifications on older vehicles with a single VIN with no federal labels. The issue here was that these older vehicles, most of the time, ONLY had 1 VIN, and, federal labels were not issued until 1970. The confusion that this memo caused halted business for a few months for many verifiers.

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