The emergency order issued by Governor Reynolds provides that 45 day temporary tags do not expire during the duration of the emergency order and also waives the requirement that title and registration applications be submitted within 30 days for the duration of the emergency order. The waiver of the 30 day titling and registration deadline was ordered by the governor so that Iowans can legally operate their motor vehicles on expired plates or without plates if the titling and registration process has not been completed. Customers who are handling their own titling and registration are not entitled to temporary tags and can legally operate for 30 days or the duration of the emergency order with no plates, provided they have a copy of the purchase agreement or bill of sale in the vehicle.
IADA is aware of no banks or funding sources that have waived the dealer/lender agreement provisions requiring that liens be timely perfected. The lien preference provisions of the US Bankruptcy Code have potentially significant consequences for failure to perfect a lien within 30 days if a customer files bankruptcy within 90 days of delivery of the vehicle. There continues to be a significant risk of recourse or charge back by funding sources if liens are not perfected within 30 days of vehicle delivery. Iowa law provides that the lien is perfected when the paperwork and payment are received by the county treasurer. Iowa county treasurers are using the date of the postmark as the delivery date when title and registration applications are mailed with payment. County treasurers are working but offices are not open to the public. IADA strongly recommends submitting title and registration applications and payment by US mail.
Bottom Line: The titling and registration waiver from Governor Reynolds does not change the federal bankruptcy provisions that require dealers to perfect liens within 30 days. Dealers need to perfect liens within 30 days of vehicle delivery or risk charge back from the funding source.