Homeland Security Issues ‘No-Match’ Letter Guidance
Dealerships may receive “no-match” letters when an employeeês name or Social Security number on an I-9 Employment Eligibility Verification or W-2 form does not match government records. Discrepancies should be addressed within 90 days. If a discrepancy persists, the dealership may have to terminate the employee or risk a finding by the Department of Homeland Security that it had constructive knowledge of an illegal alien being employed.
DHS issued a notice, effective Sept. 14, 2007, describing safe harbor procedures and how to address no-match letters from the Social Security Administration. To avoid sanctions, including penalties, dealerships that receive no-match letters should check the employee’s file to see if the discrepancy is due to a clerical error. If so, inform the SSA within 30 days. To verify a SSN, call the SSA at 800.772.6270, or go to www.ssa.gov/employer/ssnv.htm or www.ssa.gov/employer/ssnvadditional.htm. Keep records of the manner, date, and time of SSN verifications in employee files. If the discrepancy is not due to clerical error, the employee needs to confirm whether the dealershipês records are correct.
For more information, call (800)421.7105 or to visit the DHS Safe Harbor Information Center at http://faq.ice.gov/cgi-bin/ice_faq.cfg/php/enduser/std_alp.php?p_sid=6IbfqOIi. For general information on I-9 forms, see NADA’s publication L. 21-E, A Dealer Guide to Compliance with the Immigration Reform and Control Act of 1986.
New Safety Labels Now Required
As of Sept. 1, vehicle manufacturers were required to include National Highway Traffic Safety Administration New Car Assessment Program (NCAP) safety ratings on automobile Monroney labels. By law, automobiles include passenger cars and vans, station wagons, sport-utility vehicles, crossovers, and small buses under 10,000 lb. gross vehicle weight rating. Because NCAP assigns star ratings based on test performance, the new safety information label is known as stars for cars and features a one- to five-star graphic display.
NHTSA conducts NCAP testing on a rolling basis throughout the model year, but does not test all models and doesnêt always conduct all tests for each model. Manufacturers are required to add safety label information to Monroney labels within 30 days of receiving NCAP test results. NHTSA offers an explanatory brochure titled Coming to a Window Sticker Near You … It includes sample labels and can be used to help consumers understand the new safety information. The new labels reference www.safercar.gov and NHTSAês hotline.
NHTSA also requires dealerships that alter covered vehicles to attach a second label adjacent to the Monroney label stating that the vehicle has been altered. Changes made to used vehicles are not subject to alteration labeling.
Fraudulent Letter Alert
NADA reports that a number of dealers and other businesses are receiving fraudulent letters purportedly issued by the U.S. Department of Transportation requesting that current or potential contractors register in the agency’s Central Contractor Registration System, officials indicated. However, NADA’s regulatory affairs office said that DOT does not require any confidential information to be submitted to verify CCR registration. NADA recommended that all dealers verify that they are sending information to an authorized DOT official before submitting confidential company information.
An example of a fraudulent letter can be found at www.dot.gov/ost/m60/LuntLetter07_20_2007.pdf. Officials said the CCR is a legitimate government system, but to register contractors should go directly through the CCR Web site. For information on how to register in the CCR, visit www.ccr.gov.
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