Corey Thompson, director of the Enforcement Division at the Texas Department of Motor Vehicles, told the Motor Vehicle Industry Regulation Advisory Committee that the department will use risk-based factors to trigger compliance reviews and that consequences for failing a review could include loss of eligibility for quarterly license-plate allocations.
"We are working out a number of risk-based factors that will trigger compliance reviews," Thompson said. He described a failed compliance review as a misalignment discovered when staff validate physical plates on-site against the system inventory: "When we show up on-site ... there is misalignment from there."
Thompson said enforcement outcomes will be fact-dependent and not automatic for minor errors. "I'm never gonna say that it's going to be an absolute just if there's no match, that there's not a reason or a mechanism that would keep the dealer going otherwise," he said. He added that dealers will have opportunities to provide mitigating information and that the department will prioritize follow-up audits where needed to prevent unintended business closures.
Committee members asked for clarity on timelines. Thompson said the department expects to conduct requested follow-up compliance audits "within a week" in priority cases and that the department is open to including timelines in rule language. General Counsel Laura Moriarty explained the department is drafting rules aware of enforcement limitations but said staff intend to enforce the statutory 10-day destruction deadline where applicable.
Members repeatedly asked for explicit rule language to prevent abrupt loss of allocations without notice. Quintero and Thompson said the department will provide alternative pickup options and a process for dealers to request compliance reviews; staff cautioned that some enforcement decisions will be made case-by-case.