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Citing the interpretation noted in the NPRM, which specifically states that the “positive

identification style”/“posident” typeface is permitted under Part 565, GM indicated that it plans

to continue its use of the typeface in its VIN marking.

Harley-Davidson suggested that language in the NPRM regarding the “positive

identification style”/“posident” typeface “could be interpreted to mean that NHTSA was not

inclined to encourage use of the posident font. Additionally, Harley-Davidson said the terms

“positive identification style font” and “posident” refer to the same thing and noted that it uses

the typeface on some frame stampings, although not in its VIN markings.

Agency Analysis and Response:

In 1978, NHTSA issued an interpretation stating that there is no bar to using the

“posident” typeface in a VIN under Part 565. That interpretation may be found at

http://isearch.nhtsa.gov/gm/78/nht78-2.2.html. The agency is neither encouraging nor

discouraging the use of this typeface. The agency has not changed its position with regards to

this interpretation. The “posident” typeface is therefore still permitted under the amendments to

49 CFR Part 565 issued today.

10. Location Change for Vehicle Make: Possible Impact on State Regulatory Programs

Comment:

NYDEC said it is unclear if vehicle make would become more difficult to obtain if the

agency’s proposal is finalized as written. It added, “Vehicle make must be readily available to

State regulatory programs from the VIN.”

Agency Analysis and Response:

The American Association of Motor Vehicle Administrators (AAMVA) was a member of

the SAE committee that petitioned NHTSA to commence this rulemaking. If moving the vehicle

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