REG 262 odometer disclosures are one of the fastest ways a title transfer gets delayed. This guide explains how California dealers should correct mileage disclosure mistakes on a title, REG 343, or REG 262; when a new REG 262 is required; when to keep (not shred) the “bad” REG 262; and how to document exceptions with a REG 256. It also covers when an incorrect secure power of attorney (SPOA) must be discarded and replaced.
Why odometer disclosure errors are a big deal
California DMV treats mileage disclosure as a high-integrity statement. In practice, that means “clean” entries matter: if the disclosure contains an error or alteration, the disclosure can be considered void and you must re-disclose mileage on the correct document(s) before DMV will complete the transfer. DMV publishes specific correction procedures for common errors, including what replacement forms are required. https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/errors-in-reporting-odometer-mileage/
Step 1: Identify where the error is (that determines the fix)
Dealer Educator teaches a simple rule: correct the odometer disclosure on the document that DMV requires for that transaction type. When you find an error, start by locating where the mileage disclosure was (or should have been) made:
- On the odometer disclosure section of a complying title (or other complying document submitted as the disclosure).
- On the odometer disclosure section of an application form such as REG 343.
- On REG 262 (Vehicle/Vessel Transfer and Reassignment Form).
- On a secure power of attorney (SPOA) used for odometer disclosure/title release when title was unavailable.
Step 2: Use the DMV “if error is made, submit this” rules
If the error is on the odometer disclosure section of REG 343 or a complying title
When the error is made on the odometer disclosure section of an application (including REG 343) or a complying title, DMV’s correction path is to move the disclosure to a separate REG 262 and explain why the separate disclosure is attached using REG 256.
- Submit a REG 262 for the odometer disclosure.
- Submit a REG 256 (Statement of Facts) explaining why there is a separate odometer disclosure statement.
If the error is on REG 262 (Vehicle/Vessel Transfer and Reassignment)
If the error is on a REG 262, DMV requires a new REG 262. The key compliance detail for dealers is what to do with the original REG 262.
- Submit a new REG 262.
- Retain the original REG 262 when the Bill of Sale and/or Power of Attorney sections were also completed.
This “retain the original” rule matters because the REG 262 can include multiple transaction-critical sections, not just mileage disclosure. DMV procedure: https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/errors-in-reporting-odometer-mileage/
If the error is on a secure power of attorney (SPOA)
An SPOA is used when the title is unavailable at the time of sale (often because a lienholder has it). DMV explains that California no longer produces an SPOA form but continues to accept California SPOA, and that out-of-state SPOA may be used in certain situations. https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/secure-power-of-attorney/
If there’s an error on an SPOA, DMV requires:
- A new REG 262.
- Discard the incorrect SPOA.
When do “alterations” void the disclosure?
As covered in Dealer Educator’s registration and titling training, the safest approach is to treat any cross-outs, white-out, overwritten digits, inconsistent handwriting, or other changes inside the odometer disclosure statement as a void disclosure that must be re-done on a clean form. DMV’s REG 262 guidance is explicit that errors or alterations void the odometer disclosure statement and require a new REG 262 for disclosure plus a REG 256 explaining why a separate disclosure is attached. https://www.dmv.ca.gov/portal/uploads/2020/06/reg262.pdf
How to write the REG 256 when a separate disclosure is attached
DMV’s “Errors in Reporting Odometer Mileage” procedure requires a REG 256 explaining why there is a separate odometer disclosure statement when the original disclosure was on a complying title or application form and is now being replaced by REG 262. https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/errors-in-reporting-odometer-mileage/
Dealer-friendly REG 256 tips:
- Be specific about the document with the error (e.g., “odometer disclosure section of title” or “REG 343 odometer disclosure section”).
- State the reason for the separate disclosure (e.g., “error/alteration made on original disclosure; corrected by completing REG 262”).
- Do not “explain” by re-writing mileage numbers in multiple places; keep the mileage statement in the formal disclosure section of the REG 262/title.
Should you keep or discard the original paperwork?
Use this quick rule set from DMV procedure (and emphasized in Dealer Educator compliance training):
| Document with the error | What to do next | What to do with the incorrect document |
| REG 343 odometer disclosure section or complying title disclosure section | New REG 262 + REG 256 | Keep your deal jacket records per your normal retention policies; DMV focuses on submitting the corrected disclosure set |
| REG 262 | New REG 262 | Retain the original REG 262 if Bill of Sale and/or POA sections were completed |
| SPOA | New REG 262 | Discard the incorrect SPOA |
DMV procedure source: https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/errors-in-reporting-odometer-mileage/
Common dealer scenarios (and the clean fix)
Scenario A: Mileage was written wrong on the title (or REG 343) and crossed out
- Complete a new REG 262 for the odometer disclosure.
- Attach a REG 256 explaining why a separate odometer disclosure statement is attached.
- Submit with the rest of the transfer documents.
Scenario B: Customer made a mistake in REG 262 Section 3 (Odometer Disclosure)
- Have buyer/seller complete a new REG 262 (new, clean odometer disclosure).
- If Section 2 (Bill of Sale) and/or Section 5 (POA) were completed on the original REG 262, retain the original REG 262 with the application package.
Scenario C: SPOA was filled out incorrectly
- Discard the incorrect SPOA.
- Complete a new REG 262 for the odometer disclosure and submit it with the transfer documents.
Dealer checklist: prevent REG 262 mileage rejections before they happen
- Use fresh ink and write the mileage clearly (no strike-throughs, no overwriting).
- Confirm the VIN and vehicle description match the title/REG 343 before anyone signs.
- Confirm both buyer and seller sign where required; DMV notes original signatures are required for disclosure and acknowledgment of odometer mileage. https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/
- If you must replace a disclosure that was originally on a title/application, prepare the REG 256 at the same time so the transfer package is complete.
- If an SPOA is used for one transfer in a chain, plan to use REG 262 for subsequent odometer disclosures and submit both with the transfer documents. https://www.dmv.ca.gov/portal/handbook/vehicle-industry-registration-procedures-manual-2/odometer-mileage-reporting/secure-power-of-attorney/
Bottom line for CA dealers
When there’s an odometer disclosure mistake, don’t try to “initial and fix” inside the disclosure box. Follow DMV’s correction path: re-disclose on a clean REG 262 when required, use REG 256 to explain why the disclosure is separate when the error was on a title or application form, retain an original REG 262 when other sections were completed, and discard incorrect SPOA forms that must be replaced.
