Dealer - Fines for Late Submission of Title Work

Maryland dealers are required by law to submit certain customers' title application documents and related fees no later than 30 days after the vehicle is delivered to the customer. The title work and fees must be submitted on behalf of a customer who purchases a vehicle in class A, D, M or G; the dealer also may opt to provide this service for other customers. When the title work and/or fees are received by the MVA more than 30 days after the vehicle's delivery date, the MVA may assess a fine for each day late.

How does the MVA determine the title work submission date?

The MVA generates monthly internal reports that compare the vehicle's delivery date, with the date when the MVA actually receives the title work and fees. If the dealer uses the Electronic Registration and Titling (ERT) system to submit the title work and fees, the date when the information is received electronically from the ERT vendor is used as the date received.

Although reports are prepared monthly, the Business Licensing and Consumer Services (BL&CS) division only assesses fines at the end of each quarter. Typically, the BL&CS division prepares and mails a Dealer Late Titling Fine Report to each dealer who has late submissions during the previous 3 months. Information about the vehicle and the fine amounts is included in the report.

[Return to Top]

What happens when the dealer submits the title work on time but then has to resubmit the work because of errors?

On occasion, the MVA office that processes a dealer's title work discovers errors or omissions and returns the work to the dealer. The dealer must then correct the problem(s) and resubmit the title work. Depending upon the seriousness of the problem(s), the MVA may allow the original submission date to be used, rather than the re-submission date, in determining if the work is late. Typically the original submission date can be used in the following cases:

Short fee - transaction was initially rejected because the dealer fees paid were $100 or less than the fees owed.
Customer flag - transaction was rejected as a result of a flag on the customer's driving record for a parking, VEIP, red light or insurance violation.
MVA backlog - transaction was reported as late (exceeded 30 days) result of excessive backlogs at the MVA.
MVA loss or mishandling of documents - transaction was reported as late (exceeded 30 days) as a result of the loss or mishandling of title work by the MVA.
MVA failure to identify all errors - a resubmitted transaction was reported as late (exceeded 30 days) because the customer agent did not identify all of the errors on first review, and the work had to be resubmitted for a second time.
Other reasons - transaction was reported as late (exceeded 30 days) for an unusual or unique reason that an MVA manager or supervisor decides should be resubmitted under the original submission date.

[Return to Top]

What should a dealer do if it believes that the fine is unjustified?

A dealer may appeal to the Business Licensing and Consumer Services (BL&CS) division if it believes that a fine should not have been assessed. The following chart provides information about errors that could occur, and the documentation needed from the dealer before the BL&CS division can adjust the assessed fine.

Dealer's Reason for Contesting Fine	Possible Source of Error	Required Documentation
Incorrect "Date of Delivery" appears on the Late Titling Fine Report	May have occurred for different reasons.	Copy of the Application for Certificate of Title for the vehicle showing the correct "Delivery Date". The "Delivery Date" should match the date on the Temporary Tag Registration or the Transfer Certificate.
Incorrect "Date Submitted to the MVA" appears on the Late Titling Fine Report
First Submission	The MVA customer agent mistakenly recorded the TARIS data entry date as the "date submitted to the MVA", instead of the actual submission date.	Copy of the MVA Validated Transmittal Sheet, with the stamped date when the MVA received the title work highlighted.
Re-submission	The MVA customer agent mistakenly recorded the title work "re-submission date" as the "date submitted to the MVA", instead of the first submitted date.	Copy of the Rejection/Resubmission Form that reflects the initial "date submitted to the MVA". A completed Rejection/Resubmission Form should have accompanied all title work that was resubmitted by the dealer. The dealer should retain a copy of the form for its files.
Customer purchased his own leased vehicle	Because no excise tax is collected in this situation, the report may have mistakenly identified the transaction as late.	Copy of the customer's original lease agreement or a copy of the original title showing the leasing company name and the customer's name; and, Copy of the customer transaction receipt showing that no excise tax was collected.
Transaction was originally going to be processed out of state	The customer stated that he was going to title the vehicle in another state. Instead, he came back to the dealer in order to title the vehicle in Maryland. This may have prevented the dealer from submitting the title work within the 30-day time period.	Copy of the Residency Verification Form

[Return to Top]

Fees:

All title documents, excise taxes, and related fees are due to the MVA within 30 days of the date of delivery of the vehicle. A late submission fine is assessed on the 31st day after delivery, or first late day, for each transaction.
An additional daily fine for late submission is assessed on the second late day and each day late thereafter for each transaction.

Contact Information:

MVA
Business Licensing and Consumer Services
6601 Ritchie Highway, N.E.
Glen Burnie, MD 21062
e-mail: LateTitling@mdot.state.md.us

For telephone questions:

MVA Customer Service Center:	1-410-768-7000
TTY/Hearing Impaired:	1-301-729-4563