California Dealer Guide to Report of Sale (REG 51) Compliance
The focus keyphrase for this article is Report of Sale REG 51 compliance. Every California dealer must properly complete, file, and retain the Report of Sale (ROS) to stay in good standing with the DMV and to avoid delays for customers. Use this guide as a practical checklist to audit your deals and prepare for inspections or audits.
What Is the Report of Sale (REG 51)?
The Report of Sale (ROS), DMV form REG 51, is the transaction record that California dealers must complete for each retail or wholesale vehicle sale that requires registration or transfer of ownership. It documents the buyer, seller, vehicle identification, odometer, and all fees and taxes collected.
In most dealerships, completion of the REG 51 triggers issuance of temporary operating permits (TOPs), registration submission through Business Partner Automation (BPA) or paper, and the documents that must be kept in the deal jacket.
Key Elements to Complete on REG 51
To maintain strong Report of Sale REG 51 compliance, every line should be accurate, legible, and supported by backup documents in the deal jacket. At minimum, confirm:
- Dealer information: Dealer name, address, and DMV license number.
- Buyer information: Full legal names, addresses, driver license/ID numbers, and dates of birth matching identification.
- Seller information: For used vehicles, the prior owner information should match the title or ownership document.
- Vehicle description: Year, make, model, body type, VIN, color, and odometer reading. Always verify the VIN and odometer against the vehicle and title.
- Odometer disclosure: Required for most vehicles under federal and state law. The odometer reading, disclosure statement, and signatures must match all related documents.
- Purchase price and trade-in: Selling price, trade-in allowance, and net sales price must match the retail installment contract, buyers order, and any buyer-signed worksheets.
- Taxes and fees: Sales tax, registration fees, transfer fees, and any other DMV-related charges should match fee worksheets and BPA or DMV fee calculators.
- Lienholder information: If the vehicle is financed, confirm the exact legal name and address of the lienholder as required for title perfection.
Common Accuracy Checks
- Compare the VIN on REG 51 to the VIN plate, door jamb label, and title.
- Confirm buyer names and addresses match identification and finance documents.
- Match odometer figures across the REG 51, title/ownership document, odometer disclosure, and contract.
- Recalculate fees and taxes or verify against DMV/BPA fee computation to avoid under- or over-collection.
Temporary Operating Permits and REG 51
Temporary operating permits (TOPs) allow the buyer to operate the vehicle while the registration and plates are being processed. The DMV requires that the permit information correspond to a valid Report of Sale.
- The vehicle and buyer information on the TOP must match the REG 51 exactly.
- Do not issue a TOP without a properly completed ROS and supporting documents.
- Keep a copy or electronic record of the TOP in the deal jacket, linked to the ROS number.
- Track expiration dates to respond to customer questions or renewals when permitted by DMV rules.
For DMV policy on permits and registration, review the Vehicle Registration Handbook on the California DMV website (dmv.ca.gov).
Submitting the REG 51 via BPA or Directly to DMV
California dealers using the Business Partner Automation (BPA) program submit most Reports of Sale electronically. Others submit paper REG 51 packages to DMV field offices or headquarters, depending on the transaction type.
While specific timelines and methods can vary by transaction, California law requires dealers to submit registration and transfer documents, along with required fees, within a short statutory period after the date of sale. Failure to do so can result in administrative penalties and customer complaints. For official timeframes and penalties, consult the California Vehicle Code and DMV registration guides (leginfo.legislature.ca.gov and dmv.ca.gov).
BPA Program Considerations
- Ensure your BPA software profile is correctly configured with your dealer number and location.
- Enter all ROS data carefully and cross-check with the physical REG 51.
- Retain electronic submission confirmations or BPA reports in the deal jacket or in a clearly organized digital file.
- Monitor BPA error or reject reports daily and correct any issues promptly.
Corrections, Voids, and Reprints
Even with careful training, mistakes on the Report of Sale happen. Correcting them properly is an essential part of Report of Sale REG 51 compliance.
Minor Corrections
- Follow DMV guidance on acceptable handwritten corrections (such as single-line strike-through, correction, and initials) versus when a new ROS is required.
- Ensure any corrected information matches all supporting documents.
Voids and Cancellations
- If a sale cancels before delivery or funding, follow your dealer’s void process and DMV rules.
- Mark the REG 51 as void, record the reason, and retain it in sequence with other ROS forms.
- Document buyer cancellation notices, unwinding documents, or revised contracts in the deal jacket.
Reprints and Duplicates
- Limit reprints of REG 51 and TOPs to what is necessary for operations or customer requests.
- Clearly label duplicate copies and make sure the deal jacket shows which copy is the final executed version.
Deal Jacket Requirements for REG 51
For each sale, the deal jacket should clearly show the complete history of the transaction, including a fully executed Report of Sale.
- Include the original executed REG 51 or BPA printout.
- Attach copies of buyer IDs, odometer disclosures, and the title or ownership document.
- Include worksheets showing calculation of taxes and fees.
- Attach copies of temporary operating permits and any replacements issued.
- File BPA confirmations or DMV receipts as proof of timely submission.
- Include written explanations for voids, rewrites, or corrections.
California dealers must maintain books and records, including reports of sale and supporting documents, for a period specified in state law and DMV regulations. For details, consult California Vehicle Code sections governing dealer records and DMV occupational licensing regulations (leginfo.legislature.ca.gov and dmv.ca.gov).
Reconciling ROS Numbers and Log Control
Strong internal control over your ROS inventory is a cornerstone of dealer compliance. Your accounting or office staff should maintain a log of all Report of Sale numbers issued to your dealership.
- Record the starting and ending ROS numbers for each booklet or batch.
- Assign ROS numbers to each deal when the sale is written, not after the fact.
- Mark each ROS number as sold, void, spoiled, or unused in your log.
- Reconcile the ROS log regularly with deals funded, vehicles delivered, and DMV/BPA submissions.
During a DMV or other regulatory inspection, investigators often review your ROS inventory and logs to confirm that every issued number has been accounted for. Having a clear log, supporting documentation, and well-organized deal jackets is one of the best defenses during an audit.
Quick Audit Checklist: REG 51 and Deal Jacket
Use this quick checklist to confirm each sale has a properly executed Report of Sale and that you are ready for inspections or audits:
- Buyer and seller information is complete, accurate, and matches IDs and contracts.
- VIN, year, make, model, and odometer are correct and consistent across all documents.
- Sales price, trade-in, taxes, and fees match the contract and fee worksheets.
- Odometer disclosure is completed and signed as required.
- Temporary operating permit (if issued) matches the ROS and is filed in the jacket.
- REG 51 has been submitted via BPA or DMV within required timelines, with proof of submission retained.
- Any corrections, voids, or cancellations are documented and cross-referenced to the ROS number.
- The ROS number appears in your inventory log, marked with the final status of the deal.
Training Your Team on ROS Compliance
Consistent, written procedures and regular training help ensure Report of Sale REG 51 compliance even when staff members change.
- Create written step-by-step instructions for completing REG 51 and related BPA entries.
- Provide checklists for F&I, sales managers, and title/DMV clerks to follow for every deal.
- Use sample completed ROS forms and deal jackets as training tools.
- Perform periodic internal audits of recently delivered deals to catch and correct errors early.
Well-trained staff, strong recordkeeping, and consistent ROS controls reduce the risk of penalties and protect your license during DMV audits.
