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Updated August 18
NADA hosted CARS webinars on July 7, July 27, August 3 and August 17. During the webinars, NADA received thousands of questions and has consolidated and distilled them into the list below, along with responses.
Dealers should advise customers to consult NHTSA’s CARS Web site http://www.cars.gov/. A dealer-specific CARS Web site is at http://www.cars.gov/index.php/dealersupport and the CARS Hotline is 1-866-CAR-7891.
Dealers who continue to have technical problems only (i.e., need to update banking accounts, reset registration passwords, etc.) should send an inquiry to the following email address: 9-amc-nhtsa-cars-ap-supplier@faa.gov.
Don’t see your question answered? New questions may be submitted to clunkers@nada.org and NADA staff will respond.
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The foregoing summary is offered for information purposes only and is not intended as legal advice. Consult your attorney for guidance on appropriate measures your dealership must institute to comply with these requirements.
PROGRAM IMPLEMENTATION
Q. How does the program work?
A. Generally, used vehicles with a combined fuel economy rating of 18 mpg or less may qualify for a government incentive of $3,500 or $4,500. The incentive must be used to offset the purchase price or lease price of a qualifying new vehicle.
Q. When does the program start? And when does it end?
A. The program runs from July to November 1, 2009. Dealer registration for the Car Allowance Rebate System (CARS) program began at 7 a.m. ET on July 24. Once registered, dealers will receive a username and password that will enable them to submit Applications for Reimbursement. Due to an overwhelming response from consumers, Congress approved an additional $2 billion into the CARS program, which will continue the program. NADA is working with the National Highway Traffic Safety Administration's (NHTSA) to ensure a fair and orderly wind down designed to ensure that all valid deals are paid.
Q. Doesn’t the law say the program starts on July 1? What should dealers tell customers who want to purchase before the regulations are finalized?
A. Transactions completed prior to the issuance of NHTSA rule may be approved for reimbursement if they qualify for the federal incentive. Dealers who attempted to conduct transactions prior to July 24 are advised to closely review the rule’s requirements before submitting them for reimbursement.
Q. As funds run down, how can dealers protect themselves from losing $3,500-$4,500?
A. Due to an overwhelming response from consumers, Congress approved an additional $2 billion to continue the CARS program. NADA is working with NHTSA on a fair and orderly program wind down designed to ensure dealers are reimbursed for all valid deals.
Q. Can customers with more than one clunker purchase more than one new vehicle, each with its own CARS incentive?
A. No. Dealers should stress to prospective purchasers that they may not engage in a CARS transaction if they have already done so, and that doing so will subject the purchaser to a potential $15,000 fine. The CARS system is designed to reject reimbursement applications involving purchasers who have already been involved in CARS transactions. At this time, the system does not allow one to determine beforehand if a prospective CARS purchaser already has a deal pending for approval.
Q. Are purchasers limited to one CARS transaction per person or per family?
A. One per ownership: “…the agency has determined that only one credit may be issued for each transaction under the program and that once a person participates in a transaction, whether as an individual owner or a joint-registered owner of either an eligible trade-in vehicle, a new vehicle, or both, the person may not receive another credit or be named in a transaction receiving a credit under the program.”
Q. If a claim is rejected, can it be fixed and resubmitted?
A. Rejected reimbursement applications should be accompanied by reasons for the rejection. If correctable, a rejected reimbursement application may be resubmitted without penalty, but it will be treated as a new application as of the date it is resubmitted.
Q. Where can we buy the sodium silicate necessary to disable the engine block?
A. Sodium silicate is readily available from chemical or automotive supply distributors. Many ATAEs have also arranged for supplies for their member dealers. Carefully follow the instructions in Appendix B: http://www.cars.gov/files/6265_EngineDisablementProcedures.pdf.
Q. Is this program mandatory or voluntary for dealers?
A. The program is voluntary for all new-car dealers.
Q. Will dealers have to purchase additional software or services in order to participate?
A. No. A computer with Internet access and a scanner is necessary to submit reimbursement applications and supporting documents to NHTSA.
PROGRAM REGISTRATION
Q. Where can I find the Dealer User Guides on CARS.GOV?A. You should visit the following Web site:
http://www.cars.gov/dealersupport/user-guide
Q. Must dealers register in order to participate?
A. Yes. NHTSA began mailing letters on July 17 to all new-car dealers, for each franchise they operate, indicating their eligibility to register and participate in the CARS program. These letters contain Authorization Codes that must be used to separately register each vehicle franchise.
Once registrations are reviewed and approved, dealers will receive an e-mail confirmation containing usernames and passwords. NHTSA will publish and regularly update a list of participating dealers on its http://www.cars.gov Web site. For registration details, see: http://www.cars.gov/index.php/dealersupport.
Here are some more useful registration tips:
• When registering your franchise, each franchise MUST have a different e-mail address. So for each authorization code you register, there must be a unique e-mail address as this will be your username. Entering a duplicate e-mail address will result in the registration being rejected and will GREATLY increase the amount of time it takes to process your registration.
• When entering your bank information, please use the “Existing Bank” option to search for your bank by the routing number (bank number). Select your bank from the resulting list. Do not use the “New Bank” option unless you cannot find your bank in the existing bank list. Do not use the “New Branch” option — select your branch using the “Existing Branch” option. Not following these guidelines GREATLY increases the amount of time it takes to process your registration.
• When entering your address, use the State Abbreviation in CAPITAL letters instead of typing the full state name.
• When resubmitting after receiving a rejection notice, use your original authorization code.
Q. Must each franchise be registered to participate (i.e. Chrysler, Jeep and Dodge)?
A. Yes, each franchise must be registered separately using a different email address. If the same email is entered for more than one franchise, only one franchise will be accepted into the CARS database.
Q. If we did not receive a registration letter, what should we do?
A. First, ensure that the letter wasn’t misdirected within the dealership. Second, contact help@cars.gov and the appropriate OEM. OEMs were expected to begin assisting with missing registration information/authorization codes by July 31.
Q. What should we do if we have registered but are not on the CARS.gov dealer locator?
A. It can take 1-4 days from date of registration until the franchise is posted on cars.gov.
Q. Can a dealer choose to de-register from the CARS program?
A. Yes. Call the CARS Hotline at 1-866-CAR-7891.
INCENTIVE STRUCTURE
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'Cash For Clunkers' Matrix |
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Passenger Car |
Light-Duty Truck |
Large Light-Duty Truck
(6,000 – 8,500 pounds) |
Work Truck
(8,500 – 10,000 pounds) |
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Minimum Fuel Economy for New Vehicle (EPA combined) |
22 mpg
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18 mpg
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15 mpg
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Not applicable |
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To qualify for a $3,500 Voucher |
At least 4 mpg more than the trade-in vehicle |
At least 2 mpg more than the trade-in vehicle |
At least 1 mpg more than the trade-in vehicle or trade-in of a work truck |
Trade-in must be 2001 model year or older |
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To qualify for a $4,500 Voucher |
At least 10 mpg more than the trade-in vehicle |
At least 5 mpg more than the trade-in vehicle |
At least 2 mpg more than the trade-in vehicle |
Not applicable |
Q. How do I find out the combined city/highway fuel economy rating of a vehicle?
A. Dealers are expected to verify that the trade-in vehicle and the vehicle being purchased or leased are both eligible under the program. For both vehicles, the dealer will need to verify the combined fuel economy.
Go to http://www.fueleconomy.gov and use side-by-side vehicle comparison. Click on the model year of the vehicle, the make, and the model. Under the words “ESTIMATED NEW EPA MPG” in the red banner, see red number with the word “COMBINED” under it. That is the new combined city/highway fuel economy for the vehicle. For dual or flex-fuel vehicles, use the “Gasoline” combined number.
Q. Do customers receive a paper voucher?
A. No. Customers are not issued any type of physical voucher. Instead, when the dealer confirms that a customer has a qualifying clunker and has chosen to purchase a qualifying new vehicle, a credit will be applied to the purchase. The dealer will then apply for reimbursement from NHTSA.
Q. How may the $3,500 or $4,500 amount be applied toward eligible new-vehicle purchases?
A. The purpose of the CARS law is to assist eligible customers with the purchase of new, more fuel-efficient motor vehicles. Specific application of the “voucher” amount to each eligible new-vehicle purchase is up to the discretion of each eligible dealer and customer. For example, it may be applied to reduce the new-vehicle selling price, as a trade-in credit, as a down payment on financing, or in any other legitimate manner. Since state sales, use, or gross receipts tax treatment of the “voucher” may vary depending on how it is applied and the relevant state tax law, dealers may wish to contact their state or metro dealer association or state tax department for additional information. Also, be sure also to properly show how the voucher was applied on the credit application, if any.
Q. Is there a pre-approval process for dealers submitting reimbursement applications?
A. Electronic safeguards are in place to prevent duplicate applications from being submitted and paid.
Q. Can a “person” be defined as a small business or other corporate entity?
A. Yes. Person means an individual, corporation, company, association, firm, partnership, society, or joint stock company.
Q. How must supporting documents for the reimbursement application be submitted?
A. NHTSA requires that supporting documents be scanned and prefers PDF files. NHTSA staff told NADA they prefer a single PDF file under the name “All Supporting Attachments.” This will help ensure a quicker review by the CARS program staff.
OLD VEHICLE (“Clunker”)
Dealers are encouraged to closely follow the CARS User Guide for Dealers, which can located at: http://www.cars.gov/dealersupport/user-guide
Q. Is there an age limit for the clunker?
A. Yes. The clunker must be less than 25 years old (MY 1985 and newer) from the date of the transaction. Thus, some MY 1984 vehicles may not qualify depending on their production date. The month and year of the vehicle’s production can be located on the driver’s-side door frame.
Q. Is there a minimum period that the customer must own or insure the clunker?
A. Yes. Clunkers must be registered to and insured by the same owner for at least one year prior to the trade-in date. Proof of registration and insurance may be satisfied using one of several ways (e.g., registration cards, letter from DMV, insurance cards, declaration pages, etc.) See Section 599.300(b) of the CARS rule.
Q. Will customers have to have a clean title at the time of trade?
A. A copy of the clunker’s title, free of liens and encumbrances, must be submitted with the reimbursement application. Thus, if the title is held by a lien holder, a dealer cannot apply for reimbursement prior to receiving it after the payoff. Likewise, if it is lost, the dealer cannot apply until the duplicate is received.
Q. Must a clunker be drivable?
A. Yes, as demonstrated by actual operation of the motor vehicle on public roads by the dealer and purchaser.
Q. Must dealers provide customers with a “best estimate of the scrappage value of the (clunker)”?
A. Yes. The CARS rule contains a “Summary of Sale or Lease” worksheet dealers must use for each transaction. See: http://www.cars.gov/files/6265_SummaryofSaleorLeaseandCertifications.pdf. Among other things, dealers must provide an estimate of the clunker’s scrap value on that form. Dealers typically may obtain such estimates from the recycler, processor, or salvage auction they intend to use. By law, dealers can keep $50 of the scrap value toward administrative costs, in lieu of charging an additional CARS fee for the transaction. Purchasers of the new vehicle are not entitled to the actual money dealers may receive for clunkers when they are disposed of.
Q. When must a dealer disable the engine of the clunker?
A. In a rule change announced on July 31, dealers may now choose to disable the engine of the trade-in vehicle after they receive payment from the government for the credit. In other words, dealers no longer must disable the engine before submitting a reimbursement claim. However, until the vehicle's engine is disabled, the dealer must store the vehicle at a location under the control of the dealership. Dealers must disable the engine within seven calendar days after receiving reimbursement.
Q. Does this rule change apply to those deals before the new rule was issued on July 31?
A. Yes.
Q. How should a clunker engine be killed?
A. NHTSA has determined that a quick, inexpensive, and environmentally safe process exists to disable the engine of the trade-in vehicle while in the dealer’s possession. This involves removing the engine oil from the crankcase, replacing it with a 40 percent solution of sodium silicate (a substance used in similar concentrations in many common vehicle applications, including patching mufflers and radiators), and running the engine for a short period of time at low speeds renders the engine inoperable.
Generally, this will require just two quarts of the sodium silicate solution. NHTSA estimates that two quarts of this solution (enough to disable the largest engine under the program) should cost under $10, and that the time involved should not substantially exceed that of a typical oil change. Dealers must also attach a label to the engine that legibly states the following: This engine is from a vehicle that is part of the Car Allowance Rebate System (CARS). It has significant internal damage caused by operating the engine with a sodium silicate solution (liquid glass) instead of oil.
After disabling the block, the vehicle may be sent to an approved parts dismantler, shredder/crusher, or salvage auction. For more information, see http://www.cars.gov/dealer/disposal-and-salvage.
Q. How should I put the “JUNK AUTOMOBILE CARS.GOV” on the title? Handwritten? Type? Label?
A. Although not specified in its rule, NHTSA wants it handwritten and has reportedly rejected typed submissions.
Q. If a title is labeled as “JUNK AUTOMOBILE CARS.GOV” and submitted into the CARS system and later the deal is unwound, what happens to the vehicle’s title?
A. If such a situation occurs and cannot be approved under the CARS program, NHTSA claims they will work with individual state DMV to issue the consumer a new clean title.
Q. Can customers trade in more than one qualifying clunker and receive double the credit?
A. No. The program is limited to one credit per person per new vehicle. Additional vehicles may be traded in for their market value, but not for CARS credit. Also, not more than one credit may be issued for the joint registered owners of a single eligible clunker.
Q. Is the mileage cap “18 mpg or less” or “less than 18 mpg” for clunkers?
A. Except for Category 3 vehicles (“work trucks”), clunkers must have a combined fuel economy of 18 mpg or less.
Q: If the EPA mileage for the clunker qualified prior to July 24, does the transaction still qualify under the program? (Is there a grandfather clause for the EPA mileage adjustments)?
A. Certain customers and dealers relied on EPA’s fuel economy figures to qualify dealers prior to EPA changing the data for at least 76 models. If you have a specific case and NHTSA is rejecting it because of EPA's changes, please email help@cars.gov and it will be examined on a case-by-case basis.
Q. Some states do not make available archived vehicle registrations and the purchaser only has a current registration. What are our options?
A. The CARS rule requires that the purchaser provide proof of registration covering the trade-in vehicle for a period of at least one year prior to the date of the trade-in. For proof of registration, NHTSA also allows the following options:
1. A current state registration document or series of registration documents in the name of the purchaser evidencing registration for a period of not less than one year immediately prior to the trade-in; a current state registration document showing registration in the name of the purchaser and a document of title that confers title on the purchaser not less than one year immediately prior to the trade-in.
2. A current state document showing registration in the name of the purchaser and a document from a commercially available vehicle history provider evidencing registration for a period of not less than one year immediately prior to the trade-in.
Note that reimbursement applications also must be accompanied by a purchaser/dealer certification attesting to continuous registration for one year prior to the transaction date.
Q. How long will it take NHTSA to approve or reject an application for payment?
A. NHTSA must approve or reject a complete application for payment within 10 days of submission. However, note that registration and reimbursement application systems have experienced difficulties and delays and may continue to do so.
Q. Who is entitled to the total scrappage value?
A. The law defines the scrappage value as what the dealer is paid for the clunker. The law also provides that $50.00 of this amount can be allocated towards administrative costs. Dealers must disclose to the customer the estimated scrappage value on the NHTSA worksheet during the transaction, ostensibly to allow the purchasers to know how much less their clunkers with dead engines are worth in comparison to what $3,500 or $4,500 they are to receive from the government. Dealers may estimate scrappage value by getting a quote from a potential buyer or consignor.
Q. May dealers disable the trade at the buyer (dismantler/crusher/shredder or auction)?
A. Yes, as long as the vehicle is in the control of the dealer at all times.
Q. If the dealer is not disposing of the vehicle at time of claim submission, but will later, does the dealer attach the disposal certification form to the invoice?
A. No. These forms typically will be provided to dealers when clunkers are transferred. They may be attached to deals not yet submitted for reimbursement. Otherwise, dealers have 7 days following receipt to e-mail completed forms to disposal@cars.gov.
Q. Where do the labels to attach to the engine come from?
A. Dealers may print or write out their own labels, so long as they legibly state that “This engine is from a vehicle that is part of the Car Allowance Rebate System (CARS). It has significant internal damage caused by operating the engine with a sodium silicate solution (liquid glass) instead of oil.”
Q. May clunkers have salvage titles? What about outstanding bank or government liens?
A. Yes, clunkers may have branded titles, but must be free of liens and encumbrances and must be drivable. A lien payoff document accompanying the title will suffice.
Q. What does it mean that a clunker cannot be transferred more than two times?
A. A dealer must transfer it either to a recycler, crusher or shredder on the cars.gov list or to a salvage auction which, in turn, may only be transfer it to someone on the approved list.
Q. What about customers with title/registration discrepancies (i.e. deceased spouse, maiden names, car for son or daughter)?
A. At least one owner of the clunker and purchaser of the new vehicle must be the same. For CARS purposes, a person remains the same even when they change their name. In the case of a person with a maiden/married name change, NHTSA has indicated that a marriage license is sufficient proof that the customer may qualify and the dealer should proceed with the application.
Q. Some vehicles aren’t EPA rated. Do we assume that they are Class 3 clunkers?
A. Class 3 vehicles include those whose gross vehicle weight is above 8,500 pounds. They have no fuel economy rating. Other vehicles may simply be missing from the fueleconomy.gov database. EPA is working to address such missing information, e.g., some MY 2010 vehicles that only recently been obtained a combined fuel economy rating. Confirm each vehicle’s eligibility using the link on the cars.gov Web site.
Q. Can a consumer trade-in a Class 3 truck and purchase a passenger car under the CARS program?
A. No.
Q. Can a dealer strip the vehicle (tires, sheet metal, etc.) before scrapping?
A. While doing so may lower a vehicle’s resale value, nothing in the rule prohibits doing so.
Q. What does “trade-in flagged date” mean?
A. This term is defined the date of the actual trade-in. The word “flagged” is superfluous and should be ignored.
Q. What about a vehicle whose odometer is broken? Would that vehicle qualify?
A. Assuming the vehicle meets other criteria outlined in the CARS program and the dealer certifies this under penalty of law, NHTSA indicates that if a vehicle’s odometer is broken, a dealer may submit the vehicle’s mileage as 99,999 on the CARS application.
Q. Must a dealer submit all 5 pages of the deal summary or just the recap and signature pages?
A. NHTSA requests that all 5 pages of the deal summary be submitted.
Q. Are purchasers in states that don’t mandate vehicle insurance subject to the 1-year proof mandate?
A. Under a rule change announced on July 31, NHTSA will no longer require proof of insurance from Wisconsin and New Hampshire residents because these states do not require insurance. In all other states, to be eligible for the CARS Program, all clunkers must have been continuously insured for at least one year prior to the transaction. Options for proof of insurance include:
1. One or more insurance cards containing the make, model, model year, and vehicle identification number (VIN) of the clunker, but only if, taken together, the cards display on their face a continuous one-year period of insurance coverage.
2. Insurance policy documents (e.g., declarations pages) showing the same information.
3. A signed letter, on insurance company letterhead, identifying the same clunker identification information (i.e., make, model, model year, and VIN) and the period of continuous coverage for at least one year prior to the date of trade-in.
The purchaser/dealer certification that must be submitted as part of the reimbursement application also must contain an attestation that the clunker has been continuously insured for at least one year.
Q: What if a trade-in car is not listed in the category list?
A. Dealers who cannot find a trade-in or new vehicle in the drop down menus are asked to conduct a search as follows This will provide a default vehicle setting: “%VehicleMake%Unlisted%” (e.g. %Ford%Unlisted%). In the invoice description, include “trade-in vehicle not found in list.”
Q. Can I save an application and return back to it later?
A. Yes. If you find that there are missing items that are not available for attachment, select the Save button. CARS will save your invoice in an incomplete status for later submission.
Note: If you save your invoice a confirmation notice will appear on your Create Invoices page stating that your invoice has been saved for later submission.
NEW VEHICLESQ. Does the customer have to have a 60 month loan or lease or can they pay cash?
A. The law requires only that leases be for at least 5 years. Purchasers may finance without restriction or pay cash for a new vehicle under the CARS program.
Q. Are dealer demos eligible for purchase?
A. New vehicles eligible for purchase are those that have never been titled before. For example, if a demo has never been titled before it is eligible, regardless of its mileage.
Q. Does this program only apply to new American-built vehicles?
A. No. Customers may trade-in and purchase qualifying vehicles, regardless of where manufactured.
Q. Can customers combine these incentives with other offers?
A. Yes. For instance, customers may trade for a hybrid and get the clunker credit, a hybrid tax credit, and available dealer or manufacturer discounts. They also may be eligible to deduct sales tax, if any, on their next federal tax return. Dealers must show applicable incentives Summary of Sale or Lease form.
Q. Which fuel economy number must be used for dual or flex-fuel capable new vehicles?
A. As for clunkers, dealers must use the “Gasoline” combined fuel economy rating.
Q. Is the clunker credit subject to federal income tax?
A. The law specifically exempts the credit from federal income tax to the purchaser but does not address other possible tax issues. The federal tax consequences of the CARS payment to the dealer are addressed in an Automotive Alert from the IRS Motor Vehicle Technical Advisor that is available here.
Q. Is there a price cap for eligible new vehicles?
A. Yes. The new vehicle must have a base MSRP of $45,000 or less (excludes dealer or manufacturer options and accessories, taxes, and destination charges).
Q. Can customers lease new vehicles using this program?
A. In theory, but the lease term must be 60 months or more.
Q. May used-vehicle purchases qualify for clunker incentives?
A. No. The program only applies to qualifying new-vehicle purchases.
Q. What should dealers do if a new vehicle is not in the category list?
A. Dealers who cannot find a trade-in or new vehicle in the drop down menus are asked to conduct a search as follows This will provide a default vehicle setting: “%VehicleMake%Unlisted%” (e.g. %Ford%Unlisted%). In the invoice description, include “trade-in vehicle not found in list.”
REIMBURSEMENT
Q. How does the dealer get reimbursed?
A. Dealers are required to send in Reimbursement Applications with very specific information and supporting documents. Accurate and complete applications should result in approval. However, note that registration and reimbursement application systems have experienced difficulties and may continue to do so. NHTSA indicates that payments should arrive by electronic funds transfer approximately 1-3 business days after a dealer receives approval.
Q. How long will it take NHTSA to approve or reject an application for payment?
A. NHTSA must approve or reject a complete application for payment within 10 days of submission. However, note that registration and reimbursement application systems have experienced difficulties and delays and may continue to do so.
Q. Will there be an appeal process for claims that are rejected?
A. If a reimbursement application is denied, NHTSA will provide a specific reason for the denial. A dealer may reapply to the CARS program and await further disposition.
PROGRAM SUPPORT
Dealers are encouraged to closely follow the CARS User Guide for Dealers which can be located at: http://www.cars.gov/dealersupport/user-guide.
Q. How do I correct an invoice that is already submitted or completely cancel a transaction?
A. If you realize you made an error in your submission, don’t wait for NHTSA to process and reject it. You can follow four simple steps to cancel your submission.
• Send an email from your registered CARS email address from your dealership account
• Send to 9-amc-nhtsa-cars-ap-supplier@faa.gov.
• Subject line should read "REJECT {INVOICE NUMBER}" – enter in the invoice number for the deal you want stopped.
• Include in the body of the email all of your dealer contact information and the deal invoice number again.
If you wish to cancel an invoice (ex., the customer no longer wants to purchase the vehicle), follow the same steps and include "CANCEL {INVOICE NUMBER}" in the subject field along with the other steps for rejection.
Q. When attaching the supporting documents, should a dealer submit separate files for each of the documents or one single file containing all documents?
A. NHTSA has issued contrary information on this subject. Recently, NHTSA advised NADA to encourage dealers to use a single PDF file containing all documents. Note that NHTSA does not have the capability of accepting ZIP files.
Q. Can a dealer save, edit or cancel a CARS application?
A.The CARS system allows dealers to save or edit an application and return to it at a later time using the invoice number created by the dealer. NHTSA has received numerous complaints about the inability to cancel an application midstream and is working to modify the software to make it easier.
Q. Are dealers permitted to use the NHTSA CARS logo and Web address in advertising?
A. NHTSA allows the CARS logo to be used in advertisements (print, Web, or television), provided:
• It is displayed in immediate proximity to a description of the CARS program and it is not associated generally with the contents of the entire advertisement.
• No alterations are made to the CARS logo, which must include the http://www.cars.gov Web site.
• The following required disclaimer is made (which may appear as a pop-up during mouse-over on the Web): CARS is a program of the U.S. Department of Transportation’s National Highway Traffic Safety Administration (http://www.cars.gov).
• No quotes by the NHTSA Administrator or any other federal employee are included.
Q. Is there a toll-free number for dealers to call with questions on registration, inputting data in the CARS system or want to know the status of a reimbursement?
A. Dealers may call the CARS Hotline at 1-866-CAR-7891 to be directed to a Dealer Support specialist.
ENFORCEMENT/PENALTIES
Q. What are the penalties for violating the terms of the CARS program?
A. Violations are subject to civil penalties of up to $15,000 per violation. If an application is incomplete or otherwise fails to meet all the requirements of a qualifying transaction, the application will be rejected and the submitter will be informed electronically of the reason for rejection, without penalty.
Q. Must dealers keep records?
A. Dealers shall keep records of all transactions under the CARS Act and regulations there under for a period of five calendar years from the date on which they were generated or acquired.
More information from NADA will be posted at http://www.nada.org/cashforclunkers as it is made available.