Dealer Tag Log
September 24, 2010
Bruce Gould

Questions have been raised concerning tracking (logging) the use of dealer license plates (“tag”). The objective is to be able to determine who was using a tag at any given time. A log for each tag number would appear to be a good means to keep track.

If a tag is permanently assigned to an employee for their exclusive use, the dealer’s “log” must document that fact. If the employee is a salesperson, and that salesperson is allowing someone else to use that tag when they are not in the vehicle a DSD 27 should be completed. The DSD 27 may be kept in chronological order (essentially a “log”). That would satisfy the requirements of knowing who was using a tag at any given time. If a tag is assigned to a salesperson and logged as such and is in his/her control and they take a customer for a test drive (the salesperson is in the car) — I don’t believe that test drive needs to be logged.

For tags that are not assigned to an individual, a log must be maintained. For example — if a dealer keeps tags in a drawer (“house tags”) and an employee takes/is given one to go to the bank — that trip must be logged. (If the driver commits a crime or parks in a handicapped parking space the log will tell law enforcement and the dealer who had the tag.) Same goes for a “house” tag used for a test drive when the salesperson accompanies the customer. In this case, a DSD 27 is not needed, however the fact that the tag was used must be logged.

Maintaining DSD 27′s for “house” tags in chronological order for each tag number would satisfy the requirements (log) of knowing the whereabouts of a tag at all times. Making an entry in the log even if a DSD 27 is used would work in lieu of maintaining the DSD 27′s in chronological order.

We know of several instances where a dealer was sent a ticket for a “photo-red” violation. As the dealer did not keep a log for their dealer plates they had no way of determining who was driving the vehicle with the tag that ran the red light. The dealer had to pay the ticket. Same would apply if a parking ticket was placed on a car with a dealer tag and the driver decided not to pay the ticket. The dealer would be responsible for paying the ticket. In these cases, it would have helped the dealer if they had a log that identified who had the d-tag at the time the ticket was issued.