Idaho DMV Updated Imported Vehicle Titling Policy

The Idaho Transportation Department is preparing to implement recommendations from the American Association of Motor Vehicle Administrators (AAMVA) for the titling of imported vehicles. This policy will go into effect on Oct. 1 and applies to imported vehicles that:

  1. Were manufactured for use in another country and were not built to comply with U.S. federal motor vehicle safety standards (FMVSS).
  2. Are being titled for the first time in the U.S.

This includes vehicles manufactured to meet Canadian motor vehicle safety standards (CMVSS) and gray market vehicles manufactured for use in other countries.

Any of the following would indicate a vehicle has been imported:

  • Ownership document issued by a country other than the U.S.
  • Federal importation documentation presented, such as U.S. Customs and Border Protection (CBP) forms, Environmental Protection Administration (EPA), and DOT National Highway Traffic Safety Administration (NHTSA) documents.
  • The vehicle is 1981 or newer and does not have a conforming 17-character VIN. The VIN either will have fewer or more characters or will have too many numbers in positions where there usually are letters, especially positions four through 11. (Note: if the vehicle has already been titled by another state, it can be retitled in Idaho like other out-of-state-titled vehicles without meeting special requirements for imported vehicles, as it is assumed it met these requirements at the time of titling.)

The following must be submitted to title an imported vehicle:

  • Application for Certificate of Title, ITD 3337.
  • Original primary ownership document. This would typically be a title if the country of origin issues titles, or a registration otherwise. If key information on the primary ownership document such as owner and lienholder information can’t be determined because the document is in a foreign language, a certified translation is required. A used Canadian vehicle will have a registration while a new Canadian vehicle will have a New Vehicle Information Statement (NVIS).
  • Original or verified copy of a bill of sale or release of interest from each prior owner (a bill of sale or separate release from the registered owner is not required if an assignment on the registration or title has been properly completed).
  • CBP Form 7501 U.S. Customs and Border Protection Entry Summary, stamped and signed by CBP (original or verified copy). Required for legal entry into the U.S.
  • HS-7 Declaration Form from the U.S. DOT National Highway Traffic Safety Institute (NHTSA) with either Box 1, 2B, 3, or 8 declared. (Optional if DOT Bond release letter submitted, vehicle was at least 25 years old when imported, or vehicle is ATV, UTV, or motorbike.)
  • DOT Bond Release Letter – required when a non-conforming on-highway vehicle was imported for resale or commercial use by a Registered Importer (Box 3 declaration on HS-7 form)*.
  • Indemnifying Affidavit certifying there are no liens other than any listed on the title application. In lieu of this, a lien search report may be provided from the agency that maintains lien records in the country/province that issued the ownership.
  • VIN Inspection for Canadian vehicles.
  • MVI Statement of Facts for gray market vehicles. If waived by an MVI, VIN Inspection.
  • Odometer conversion statement — required only when all of the following occur:
    • The odometer has been converted from kilometers to miles.
    • The title is being issued with an odometer reading.
    • The odometer status is “Actual.”

The statement must include the year, make, vehicle identification number, and the original reading in kilometers as well as the mileage to which the new speedometer assembly was set. The statement is completed by the technician who did the work.

If the odometer device simply has buttons for switching from kilometers to miles, a statement from the VIN inspector to this effect will suffice in lieu of a technician’s conversion statement.

*All Gray market and Canadian vehicles less than 25 years old that were imported for resale must be imported by a registered importer (RI) under Box 3 of the HS-7 form. The RI must post a DOT conformity bond and must modify the vehicle to meet FMVSS and resolve any open recalls within 120 days. The RI must submit evidence to NHTSA in a conformity package that demonstrates the vehicle has been modified to meet FMVSS and all outstanding manufacturers’ recall notices have been addressed. If NHTSA approves, it will issue a bond release letter. If the vehicle has not been brought into conformity within 120 days, it must either be surrendered to the DOT or exported. The vehicle generally cannot be titled and registered until a DOT Bond release letter has been issued. However, if the RI states on an indemnifying affidavit that more than 30 days have passed since the conformity package was submitted to NHTSA and NHTSA has not responded, title can be used but will carry the notation, “DOT BOND RLS PENDNG.” This notation may be removed if the title is subsequently submitted with a bond release letter.

Canadian and gray market vehicles cannot be salvage, repaired salvage, or reconstructed vehicles.

Titles for Canadian vehicles that were imported for personal use only and not for resale (Box 2B declared on NHTSA HS-7 declaration form) will be issued with the brand, “Canadian Vehicle”.

When a gray market vehicle was at least 25 years old at the time of import and is being titled without a DOT bond release letter, the title will be issued with the brand, “Gray Market – Exempt from FMVSS Compliance.”

When a Canadian vehicle was at least 25 years old at the time of import and is being titled without a DOT bond release letter, the title will be issued with the brand, “Canadian Vehicle – Exempt from FMVSS Compliance.”

Additional information regarding CBP and DOT importation requirements may be found online.

Question of the Week

Q. Does a power of attorney document have to be filed with a court or recorded with the county to be effective?

A. In most cases, no. The only circumstance where a power of attorney document needs to be filed is when it will be used to perform real estate transactions, in which case, it needs to be recorded with the county. However, filing the document with the court would allow the member to obtain certified copies should they be needed to satisfy the requirements of financial institutions, creditors, or other interested parties.

Compliance Alerts

National Credit Union Administration

NCUA MDI Mentoring Grant Round Reopens Oct. 11: The NCUA announced that federally insured credit unions with both the minority depository institution and low-income designations are eligible to apply for the NCUA’s MDI mentoring grants between Oct. 11 and Oct. 29.

Q2 2021 State Credit Union Data Report Now Available: The NCUA released a report showing the performance of federally insured credit unions. The credit unions experienced strong asset and share-and-deposit growth over the year ending in the second quarter of 2021.

Post-Examination Survey Pilot: The NCUA released Letter to Federal Credit Unions 21-FCU-05 which provides information about the piloting of the new post-examination survey that will allow credit unions to provide timely feedback to the agency while helping standardize the feedback process.


Third-Party Sender Rules and Responsibilities: NACHA has released operating rule updates to clarity the roles and responsibilities of Third-Party Senders (TPS) in the ACH Network by addressing the existing practice of Nested TPS relationships, and making explicit and clarifying the requirement that a TPS conduct a Risk Assessment. The rule went into effect on Sept. 20.

Office of Foreign Assets Control

OFAC has updated the SDN list as of Sept. 16. The last update prior to this was Sept. 3.

­­­­­­­­­­­­­­­­­­­­Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News, Compliance News, Compliance Question.