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there was 16 errors in over 30,000 documents, & they said that was unacceptable
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Under the vague rules, they can do that.
I know of another case with a similar ratio. The dealer pointed out that the overwhelming majority of his paperwork was fine, and that the small number of errors were unintentional.
The response was, "well, you got 20,000 of them right, so you know what you're doing. Therefore, the 20 or so you got wrong constitute
willful violations."
This is the sort of pressure dealers have. If the administration doesn't get any overt restrictions passed through the legislature, another form of attack might be such dealer harassment.