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Published Article

Georgia Enacts Digital License Plate Regulations, Effective October 1st

Read Time: 2 mins

Beginning October 1, 2022, in lieu of the traditional metal license plate issued by the Georgia Department of Revenue (“Department”), motor vehicle owners may display a digital license plate provided by a state-approved digital license plate provider. The final rule, effective October 1, 2022, was published in June. Georgia is the fifth state to approve digital license plates, following Arizona, California, Colorado, and Michigan. (Earlier this year, Texas approved such plates for commercial fleets of twenty-five or more vehicles, but it has not yet approved them in non-commercial applications.)

Digital license plates typically include a processing unit, storage media, and wireless connectivity all built into an electronic display—similar to a tablet e-reader and roughly the same size as a traditional license plate. However, while such plates may look like a traditional license plate, the technology makes it easier for vehicle owners to maintain their title, registration, and other vehicle records—essentially eliminating DMV visits altogether. Conversely, the technology also makes it easier for creditors to track and locate vehicles (such as for repossession purposes) and for the state to monitor citizens’ driving habits and general whereabouts—all of which raise legal, privacy, ethical, and safety concerns.

Georgia’s new rules define “digital license plate” as a license plate that receives wireless data communication to display information electronically. Only persons or entities approved by the Department may supply such hardware and services to vehicle owners. Further, each device must be certified by the Georgia State Road and Tollway Authority as complying with state readability standards, among other requirements. (The Department has also published design guidelines.) Of note, the Department will still issue a metal license plate, and vehicle owners must keep the Department-issued metal plate in the vehicle at all times.

Going forward, expect more states to adopt similar laws. Several jurisdictions are already exploring the feasibility and viability of this technology, including Florida, Illinois, and Texas.

Reprinted with permission from the American Bar Association’s Business Law Today September Month-In-Brief: Business Regulation & Regulated Industries.

Insights

Published Article

California Expands Digital License Plates, Ends Pilot Program

November 11, 2022

Effective January 1, 2023, all California vehicle owners will be able to display a digital license plate in lieu of a traditional, state-issued license plate. Assembly Bill 984—approved by the governor on September 29, 2022—effectively ends California’s multi-year pilot program, which capped digital license plates at roughly one-half of one percent of the state’s motor vehicles. California will join Arizona, Colorado, Georgia, and Michigan as states that have approved digital license plates for widespread use among the motoring public.

Presentation

Compliance Matters, Including Preparing for Regulatory Examinations

October 26, 2022

Mark Edleman (Cleveland) will lead a roundtable discussion "Compliance Matters, Including Preparing for Regulatory Examinations" on October 26, 2022, at the 2022 Auto Finance Summit in Las Vegas, Nevada. The Auto Finance Summit is the Premiere event for those in the auto finance industry to learn and network.

Published Article

Colorado Becomes Fourth State to Approve Digital License Plates

August 30, 2022

Effective August 10, 2022, the owner of a Colorado registered vehicle may display a “digital number plate” in lieu of one or both of the plates traditionally issued by the Colorado Division of Motor Vehicles (“DMV”), as long as the registration number and expiration date are clearly visible at a distance of one hundred feet in normal sunlight. The legislation was signed by the Governor on April 22, 2022. Colorado is the fourth state to enact such legislation, following Arizona, California, and Michigan.

Published Article

FTC’s Proposed Dealer Trade Rules Sets Sights on “Add-on” Product Sales

August 12, 2022

On July 13, 2022, the FTC’s proposed Motor Vehicle Dealers Trade Regulation Rule, was published in the Federal Register. The FTC’s stated purpose of the proposed rule is to "protect consumers and honest dealers by making the car-buying process more clear and competitive". More specifically, the FTC believes consumers do not know the true cost of the vehicle they purchase and finance, and that consumers unknowingly purchase or are tricked into purchasing Add-on products without knowing its costs, benefits, that the Add-on products are optional, or that they are even purchasing Add-ons for the vehicle at all.