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Ferrari stated, “Regarding the possibility to distribute old manufacturer identifiers no

longer in use, we believe that they should be retained by the same manufacturer to avoid possible

confusion in case they are given to other manufacturers.”

Agency Analysis and Response:

The agency does not see a need to take any action at this time beyond adopting the

changes discussed in this final rule. As previously noted, vehicle make has been moved from the

manufacturer identifier to the second section of the VIN. This should substantially reduce the

need to issue new large manufacturer WMIs, thus extending the remaining supply of 400-450 of

these manufacturer identifiers.

In addition, the agency, through its contract with SAE for the issuance of manufacturer

identifiers, has begun the process of identifying companies with large manufacturer identifiers

that are no longer in business so that those identifiers may be returned to the system. The agency

is also identifying companies that were issued large manufacturer identifiers that, through

publicly available data, the agency knows do not produce more than 500 vehicles a year, the

current threshold for being considered a large manufacturer, or 1,000 vehicles a year, the

threshold in this final rule, under Part 565. The agency anticipates that a number of large

manufacturer identifiers will be returned to the system as a result of this process as well.

9. Posident Typeface

Comments:

While NHTSA did not propose any specific action relating to the “positive identification

style”/“posident” typeface, the subject was addressed in the NPRM and two commenters

specifically commented on it.

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