What Happens When the Temp Tag System Goes Down?
Updated: May 22, 2019
Many of you remember last fall when a contractor cut a cable somewhere in the Denver Metro and disabled the ability to print temporary registration permits across the state. This raised a series of questions about what should be done in case the system goes down again. Sending customers to the county DMV raised a whole host of issues, given that the county suffered the same outage the dealers did.
This past week, the Division of Motor Vehicles finalized a rule addressing the situation. Structurally, it will fit into Rule 34 of the existing regulatory framework, under 1 CCR 204-10.
As a disclaiming issue, this rule provides a process for recognized outages only. If a dealer realizes that their system access is down the first step is to contact the state, for the purpose of confirming a recognized outage, not just a loss of access from the dealer terminal. If a dealer unilaterally implements this solution in a non-recognized outage, it will be ineffective.
As the dealer confirms verbally with the state, the state will at the same time authorize the dealer to issue analog permits. This means hand-written. They will otherwise work the same as printed temp tags and continue to require a “temp tag holder.”
Prior to issuing the hand-written temp tag, the dealer is still required to check for a Secured and Verifiable Identification. Once this is complete, the dealer may use the form provided by the State and write the Dealer ID number (with leading zeros for those less than six digits), month/day/year of issuance, time of issuance, and VIN/Color/Make/Model/Year/Body.
This handwritten tag will be good for 36 hours. At the conclusion of the system outage, the customer should return to the dealer for a real temporary registration permit. The dealer should issue to the customer a letter on dealership letterhead with the same information as well as the dealer’s contact information.
Finally, for those handwritten tags, the dealer must also keep a copy of the analog permit and the dealership letter with the deal jacket for future inspection.
For those of you pointing out that the new Rule 34 qualifies this process as relevant “outside of business hours”, we have confirmation from the Division that the same process will apply during business hours, beginning with the verbal authorization from the state that the system is down.
See also: Regulations: Temporary Registration Permits.
If you have any questions, please contact Matthew Groves at firstname.lastname@example.org or 303-282-1449.