AFSA Government Affairs official: Electronic title rollout ‘risks introducing significant compliance and operational burdens’

AFSA Government Affairs official: Electronic title rollout ‘risks introducing significant compliance and operational burdens’
Bill Himpler, President and CEO of the American Financial Services Association (AFSA) — Instagram.com
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Elora Rayhan, State Government Affairs Analyst at the American Financial Services Association (AFSA), expressed concerns in a formal letter regarding Oklahoma’s upcoming mandatory electronic lien and title program. She said that the initiative lacks essential stakeholder engagement and poses compliance challenges.

“With less than three months remaining, NTSF members are concerned that access to business rules, response to stakeholder questions, etc. are not available,” said Rayhan. “The portal does not support batch processing, a standard function in nearly all modern ELT systems. We respectfully urge Service Oklahoma to delay the July 1, 2025, ELT effective date until all approved service providers have been onboarded.”

The statement from AFSA comes amid growing concerns over Oklahoma’s impending transition to a mandatory electronic lien and title (ELT) system, which is set to take effect on July 1, 2025. AFSA and its National Title Solutions Forum (NTSF) have expressed apprehension that the program’s current implementation timeline and lack of comprehensive stakeholder engagement could disrupt lien perfection and titling processes for both consumers and lienholders. They urge Service Oklahoma to adopt a more collaborative approach, ensuring the ELT system is fully functional and integrated with all relevant providers before the mandate takes effect, as detailed in their recent comment letter.

According to the American Association of Motor Vehicle Administrators (AAMVA), an ELT system provides an electronic means of updating lien information on titles between a jurisdiction’s motor vehicle agency and lienholders. Such systems can reduce handling, storage, and mailing costs associated with paper titles, significantly decreasing the time dealers must wait before selling a vehicle post-lien release. However, AAMVA emphasizes that for jurisdictions to fully realize these benefits and ensure fraud prevention, ELT participation should be mandatory for all dealers and lenders, highlighting the importance of comprehensive implementation strategies.

Rayhan serves as a State Government Affairs Analyst at AFSA, where she engages with state-level legislative and regulatory issues impacting the financial services industry. A UC San Diego graduate with a B.S. in Economics, she brings prior experience in business operations and legal support, including roles at IDQ and Gerson Law Firm APC.



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