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The members of the committee representing operators of data systems that utilize the 17-

character VIN system indicated that there would be some costs involved in making software and

other modifications to data systems, but that those costs would be extremely small compared to

what would be required to deal with an expanded number of VIN characters. The petition noted

that “any increase in the quantity of characters beyond the current seventeen would require

massive software changes to all programs that use a motor vehicle VIN, and would affect not

only automotive OEM’s, but also state DMV’s, local governments, insurance companies, law

enforcement agencies, research companies, NHTSA’s National Center for Statistics and

Analysis, as well as others.”

Regulatory Flexibility Act

Pursuant to the Regulatory Flexibility Act (5 U.S.C. 601 et seq., as amended by the Small

Business Regulatory Enforcement Fairness Act (SBREFA) of 1996), whenever an agency is

required to publish a notice of proposed rulemaking or final rule, it must prepare and make

available for public comment a regulatory flexibility analysis that describes the effect of the rule

on small entities (i.e., small businesses, small organizations, and small governmental

jurisdictions). The Small Business Administration's regulations at 13 CFR Part 121 define a

small business, in part, as a business entity "which operates primarily within the United States."

(13 CFR 121.105(a)). No regulatory flexibility analysis is required if the head of an agency

certifies the rule will not have a significant economic impact on a substantial number of small

entities. SBREFA amended the Regulatory Flexibility Act to require Federal agencies to provide

a statement of the factual basis for certifying that a rule will not have a significant economic

impact on a substantial number of small entities.

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