Public comments for: PVB Fleet and Car Rental Program First Penalty Amendment

Comments

Comment:
Please see document attached.
Supporting Document:
Agency: DOF
Comment:
The language upon which the Department of Finance can base termination is overly broad and vague. There is no specificity with regard to WHAT aspect of procedural requirements, if not complied with, results in the termination. Can a clerical error? A postmarked date? The burden is currently on the participant to submit timely information regarding the renter. This is done online. What if there is a software problem that causes a delay in the transfer of information. What is the remedy if one is terminated? Can one re-register? How long does this take? Is there a penalty waiting period to re-register. Even a one month period out of the program can result in overly burdensome costs to a small fleet owner. In addition, the $350 amount for unpaid summonses in judgement is too low. Where a small fleet owner handles dozens, if not hundreds of summonses each month, it is unduly harsh that two or three summonses, with penalties and interest, should cause his termination from the program. A more realistic amount should be inserted, perhaps $1000.00
Agency: DOF