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NICB said NHTSA’s VIN regulation “will soon allow more than one vehicle to have the

same Vehicle Identification Number (VIN). If the agency allows the VIN to become anything

other than a truly unique identifier, it will cripple enforcement of the Anti-Car Theft Act, the

Motor Vehicle Safety Act, the Imported Vehicle Safety Compliance Act and a host of other

Congressional mandates to protect Americans from car theft, salvage fraud and death or injury

on the nation’s highways. It would also jeopardize counter-terrorism efforts, especially the

investigation of car bombings.” NICB urged the immediate adoption of a final rule with an

effective date of November 1, 2008.

NICB said, “NHTSA’s proposed effective date for MY 2010 cars – September 1, 2009 –

is far too late because VINs for any new model year get assigned months before new cars arrive

in dealers’ showrooms. NICB’s Shipping and Assembly File, which includes nearly all motor

vehicles produced for sale in the United States, typically receives from manufacturers some pre-

production VIN assignments before the end of the calendar year that is two years before the

model year. In other words, NICB will begin to receive assignments for MY 2010 cars in

November 2008. In any case, manufacturers assign VINs toward the beginning of the production

process, not on their date of sale, so NICB will receive large numbers of MY 2010 VINs by

April, 2009, in anticipation of consumer sales in September, 2009.” Failure to have a new

regulation in effect by November 2008 “will cause unneeded confusion, expense, time to obtain

and add decoding for two MY 2010 formats and possible computer conflicts with VIN decoding

for MY 2010 vehicles,” NICB said.

Ford cautioned that delay of publication of the final rule will cause the company to incur

costs and/or cause delays in the manufacturing of vehicles assigned VINs under the current Part

565. The company noted that under a U.S. Environmental Protection Agency regulation, 40

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