The information contained in the file was entered by dealers and could be changed only by dealers (or by NHTSA under very narrow circumstances; see CARS Data Dictionary for details) to maintain accountability. As a result, there are some inconsistencies. For some fields dealers entered the information in a variety of formats (such as some phone numbers with a dash and others without a dash) and in other cases the data were mistyped (such as switching two digits of the phone number). Two additional fields (trade-in insurance start date and trade in NMVTIS flag date) were optional and frequently have missing values.
Three caveats are worth noting. The first involves the dates entered by the dealers. The CARS invoice date was a default date provided by the system when the invoice (transaction) was created, but the dealer could override with a different date. Generally, a valid CARS invoice date ranges from July 27, 2009, through August 25th, 2009. However, there are some valid dates outside of this range because of pilot testing before July 27th and transactions processed through the regulatory exception process after August 25th. The CARS sale date, the trade-in registration start and expiration dates, and the optional trade-in insurance start date also were provided by the dealer in the transaction form. These transactions may have information that was mistyped by the dealer. In cases where the required documents submitted with the invoice indicated an eligible transaction but conflicted with the sale, registration or insurance dates in the transaction form, the invoice was accepted by the reviewer based upon the supporting documentation.
The second caveat involves the vehicle identification number (VIN) for both the new and the trade-in vehicle. The VIN is a 17 character long serial number that uniquely identifies the vehicle and that typically follows a standard format. Both the new and trade-in VIN may contain mistyped information by the dealer, resulting in a VIN that appears to be nonstandard. For example, the dealer may have switched two characters or entered one wrong character such as a “5” in place of an “S”. In addition to mistyped information, some VINs may contain place holder characters entered by the dealer at NHTSA's direction to override a duplication error resulting from another dealer entering the same VIN by mistake or as part of an incomplete transaction. (Without this step, complying transactions would continue to be rejected.) It is also the case that some vehicles are titled with nonstandard VINs, and the trade-in VIN was compared against the VIN on the title. Finally, in some transactions it appears that the dealer may have reversed the new vehicle and trade-in VINs.
The third caveat involves the vehicle categories and fuel economy (miles per gallon) for the new and trade-in vehicles. In some instances the vehicle categories of the new and trade-in vehicle or the fuel economy of the two vehicles does not appear to conform to the requirements of the regulation for a valid CARS deal. NHTSA is aware of these issues and continues to research and investigate. One reason is that the EPA updated the fuel economy data on the website at fueleconomy.gov in conjunction with the CARS final rule, which affected the eligibility of certain vehicles under the CARS program. Deals that had been completed based upon the old information were accepted as valid transactions even though the new information makes it appear that the transaction is not valid. NHTSA also has identified cases where the vehicle category was incorrectly entered by the dealer, which made the deal appear to be invalid, but the deal is valid under the correct category.
NHTSA continues to review and research CARS cases for compliance. We are finalizing a data quality plan to identify and correct data integrity issues. In the instances described above where data issues involve the possibility of improper payment, NHTSA is investigating the underlying transactions and will take corrective action when necessary as part of our ongoing CARS enforcement effort.
