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08/06/2019

Registration and Titling Changes and How They Affect You!

by Caroline Mantel, BoatHistoryReport.com

Did you know that every state has a Boating Law Administrator, or BLA, that is responsible for helping to develop and shape public policy for recreational boating safety in that state?  Collectively, these BLA’s form the National Association of Boating Law Administrators, or NASBLA which you may have heard of.  The US Coast Guard is also an integral part of NASBLA and works with the BLA’s to ensure their state’s are following policies and guidelines, using boating grant money appropriately, and know and implement the latest boating safety regulations.  NASBLA collectively gets together twice per year.

NASBLA employs a committee structure to identify issues and address needs in the recreational boating safety public policy realm. NASBLA’s committees function as the primary source, sounding board and national policy-setting forum for each of the significant program areas addressed in the National Recreational Boating Safety Strategic Plan: Education and Outreach; Enforcement and Training; Engineering, Reporting, and Analysis (ERAC; Paddlesports; and Vessel Identification, Registration, and Titling (VIRT). These committees develop best management practices, model procedures, model acts, position papers and other products.    

In addition to the state boating agency members, the committees include broad representation from recreational boating professionals throughout the boating industry, the nonprofit sector, international interests, the boating public, and federal and local agencies. 

For the past several months, several committee members and USCG representatives have had monthly or weekly calls to finalize several issues revolving around state-assigned Hull Identification Numbers (HIN’s).   Boat History Report has been actively involved in NASBLA and with issues pertaining to boating safety and registration, titling, and documentation consistency issues.  As such, I, as the Vice-Chair for the VIRT Committee, had the opportunity to present during the BLA Workshop on the issues and final guidelines that will be made into a USCG Policy.

The first issue was what format to use when assigning a state assigned HIN.  As you may know, in 1972 Federal regulations were passed that required the HIN of a vessel to use a standard format.  That format was later updated in August 1984 to what is the current format:  characters 1-3  form the Manufacturer Identification Code (MIC); characters 4-8 are the serial number with the only requirements being the exclusion of the letters I, O, and Q; the 9th character is a letter A-L that represents the month of certification; character 10 represents the certification year; characters 11-12 are the model year of the vessel.  As boats age, the HIN is not always visible or legible due to things such as wear and tear, theft, re-fit, and vandalism. Therefore, a state has the ability to issue a new HIN to a vessel so that the vessel can be registered, documented, insured, financed, etc…

Through the work of NASBLA’s VIRT committee, and in partnership with the USCG, a standardized state-assigned HIN format has been finalized.  All state-assigned HIN’s will begin with the state abbreviation followed by the letter Z to form the first three characters- for example, Florida will always be FLZ.  States can then assign the serial number portion at their discretion.  The 9thposition will always be a letter A-L corresponding to the month (Jan-Dec) the HIN is issued (for all state-assigned HIN’s issued in May, the 9th character will be E) and the 10-12th characters will be the year the HIN is issued.

An example of a Florida state-assigned HIN issued in May 2019 would be FLZ12345E919.

The next issue was what to do on a registration document when the year of the vessel is unknown for a state assigned HIN.  The VIRT committee and USCG partnered with BoatUS Insurance to determine the best solution for an unknown model year.  Through many conversations, it was determined that in the case of an unknown model year, registration documents will display 1111 as the year.

How does this affect you as the broker?  In January 2017, new Federal regulations were implemented (USCG-2003-14963) that required all states to verify a vessel’s hull identification number before performing any action against the vessel (such as registration, titling, etc…).  Verification could be in the form of a signed affidavit, pencil tracing, photo, inspection, or however the state deems appropriate.  If the HIN does not comply with the required HIN format, the state is to email the USCG who would then contact the manufacturer to correct the HIN.  If the manufacturer is no longer in business, the state is to issue a state assigned HIN to the vessel.  This means that you, as the expert guiding your clients, should verify the HIN prior to representing the vessel or putting it under contract.  If the HIN is not in compliance, your clients could have trouble registering, titling, documenting, insuring, or financing the vessel as the HIN itself will be required to be updated or replaced.  Additionally, if you have registration paperwork that shows a model year of 1111 and a state assigned HIN, determining the actual age of the vessel or manufacturer of the vessel could be very difficult and create confusion for your clients.  You should be prepared to explain to them why their vessel has a state assigned HIN and what the model year 1111 actually means. 

For any additional questions on this topic or others relating to hull identification numbers or registration, titling, and documentation issues, feel free to reach out to me directly at 1-800-441-7599, ext 199 or Caroline@boathistoryreport.com.

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