A provision in Michigan's HB6361 imposes penalties on dealers who miss the 21-day title-transfer window—and most don't know it exists.
Most Michigan vehicle dealers don't realize they're now operating under a new penalty structure for late title transfers. Buried in HB6361, which amends the Michigan Vehicle Code, is a provision that could cost your dealership $50 to $100 per transaction—plus put your license at risk.
Under Section 217, subsection (4) of the amended Michigan Vehicle Code, dealers who fail to apply for title and secure registration plates within 21 days of a vehicle sale now face a mandatory late fee. The amount depends on your dealer classification:
These fees stack on top of standard registration and title fees—they're not replacements. And they're not optional. Miss the window, and you owe them.
The 21-day requirement itself isn't new. What's new is the teeth behind it. Before HB6361, missing that window was a compliance issue. Now it's a financial one, and a serious one if you're processing volume.
For a used-car dealer moving 10 vehicles a month with even a 5% late-filing rate, that's $600 annually in penalties alone—money that doesn't go to your business. For larger operations, the exposure is proportionally higher.
More critically: repeated or systematic late filings can trigger license suspension or revocation under Section 249 of the Vehicle Code. A suspended or revoked dealer license isn't a fine. It's a shutdown.
HB6361 is effective now. There is no ongoing grace period. Michigan did allow a temporary 30-day relief window during the COVID-19 pandemic (March 31, 2021 through August 1, 2021), but that window closed nearly three years ago and is not available anymore.
If you're still operating on the assumption that you have flexibility here, you don't.
The fix is straightforward: audit your title-application process. Identify where delays happen—whether in document collection, submission, or tracking—and tighten it. Twenty-one days is tight but doable if your workflow is clean.
If you're currently sitting on any late filings, contact your Secretary of State office. Catching it yourself before an audit is better than being caught.
HB6361 also ties to HB6347, so if you're reviewing dealer regulations, check both bills to understand the full scope of changes.
Source: HB6361, amending MCL 257.58b and 257.217 of the 1949 Michigan Vehicle Code; Section 217, subsection (4).