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.
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