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make from the first to the second section of the VIN has an impact on State regulatory programs,

the AAMVA would presumably have discussed that matter with the committee. The agency

does not believe that moving vehicle make from the first to the second section of the VIN will

have any impact on the availability of this information to state programs. The agency is

therefore taking no action today in response to this comment.

11. Alternative Characters


Harold R. Brink, a private individual, submitted comments recommending that symbols,

such as “!@^%&,” be used in the VIN to expand the number of unique VINs available.

Agency Response

We do not believe that it is necessary to adopt the use of symbols at this time. The

changes proposed in the petition and those adopted in this final rule provide a sufficient number

of unique VINs to assure the continued existence of the current VIN system, with the use of only

numeric and alphabetic characters, for at least 30 additional years.

12. Direction VIN Plate Should Face


NYDMV asked that Part 565.4(f) be amended to require that the characters of the VIN

plate face the front of the vehicle because it has encountered grey market vehicles with the VIN

facing the driver, which, in some cases, makes the VIN difficult to read.

Agency Analysis and Response:

Section 565.4(f) specifies the approximate location of the VIN, the minimum size for the

type, and the requirement that the VIN must be “readable.” The section does not prescribe the

direction in which the VIN plate must face. The agency is not aware of driver facing VIN plates

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