difference. Some dealers might have noticed that model contracts (either bought from vendors or printed from software) may look different. In fact, it is a requirement to use new contracts if you would like to use the 2nd disclosure method. Since Federal Regulations require contracts to name the parties that receive fees, the new program requires inspection charges split between those that receive the fee.
Contracts in use prior to the “Two Steps, One Sticker” program contained a single line item for inspection charges. This was acceptable when the entire fee was collected at inspection (a provision in the contract disclosed that a portion of the fee was retained by the inspection station). Now, if using the second disclosure method, the single line item for inspection must also contain sub-totaling identifiers. The disclosure should break out the portion paid to the state (VTR-500-RTS) and the portion paid to the inspection station (inspection report). The changes to the model disclosure are present in line K of the graphic:
Dealers are free to choose either of the two methods. However, if a dealer chooses the 2nd method (all in the inspection line), they must ensure the contract is correct. A separate itemization of the inspection fee should show the amount paid to the state and the amount paid to the inspection station. If charges or disclosures are found to be incorrect during OCCC exams, corrective action will be required.
Rudy Aguilar is the Director of Consumer Protection at the Office of Consumer Credit Commissioner (OCCC). In addition to motor vehicle installment sales, the OCCC supervises installment lenders, payday & title lenders, pawnshops, and certain real estate transactions.
I. Government License and registration fees
J. Government certificate of title fee
K. Government vehicle inspection fees
to state $________ to inspection station $________
L. Deputy service fee paid to dealer
$________
$________
$________
$________
7 Texas Administrative Code §84.808(8)(E)