CR-78 Form: NY Dealer & Transporter Regulations (PDF)

CR-78 Form – The CR-78 form is the official New York State Department of Motor Vehicles (DMV) document outlining Motor Vehicle Dealers & Transporters Regulations (Part 78). It serves as the essential operating guide for anyone registered as a motor vehicle dealer or transporter in New York. This comprehensive PDF details registration requirements, sales procedures, recordkeeping, advertising rules, temporary registrations, dealer plates, and penalties under Vehicle and Traffic Law §415.

Whether you’re opening a dealership, applying for transporter plates, or ensuring compliance as an existing business, the CR-78 PDF provides the current rules you must follow. The document is available as a free download directly from the NY DMV website and is regularly referenced as the authoritative source for dealer and transporter operations.

What Is the CR-78 Form and Why Does It Matter?

The CR-78 is not a simple application form but the full text of the Commissioner’s Regulations (Part 78) for motor vehicle dealers and transporters. Published by the NY DMV Office of Vehicle Safety & Clean Air, it explains how to legally buy, sell, or transport motor vehicles, motorcycles, and trailers (excluding mobile homes) in New York State.

Key purpose:

Ensures all dealers and transporters register properly with the DMV.
Prevents unlicensed or improper vehicle sales.
Protects consumers through strict recordkeeping, warranties, and disclosure rules.

The latest version (revised as of 7/22 with amendments through 2016) remains the current standard, with no newer replacement listed on the official DMV site as of 2026.

Who Must Register Under CR-78 Dealer & Transporter Rules?

You must register as a dealer if you:

Sell or offer for sale more than five motor vehicles, motorcycles, or trailers in any calendar year.
Display or permit the display of three or more vehicles for sale at any one time or within any one calendar month on premises you control.

Retail dealers sell to the public (in whole or in part).
Wholesale dealers deal exclusively at wholesale.

Transporters need separate registration if they move vehicles for delivery, repair, or improvement (e.g., from factories or between dealers). Persons buying vehicles solely for dismantling or scrap are generally exempt unless 25% or more of their sales are classified as salvage (then they need dismantler registration).

Note: New motor vehicle dealers may also qualify for a provisional registration while their full application is reviewed.

How to Apply for NY Dealer or Transporter Registration?

Applications are submitted using the Original Facility Application (VS-1D) along with supporting documents listed in VS-142 (Facility Requirements – Dealers/Transporters). All requirements in CR-78 must be met, including:

Proof of business name (corporation filing, DBA certificate, etc.).
Driver licenses or ID for all owners/officers.
NYS Tax ID or Sales Tax Certificate.
Surety bond (amount varies by dealer type and sales volume).
Proof of Workers’ Compensation and Disability Insurance.
Lease or ownership proof for the business location.
Franchise agreement (for new vehicle dealers).

Submit completed paperwork to:
Vehicle Safety Services, Application Unit
6 Empire State Plaza, Room 220, Albany, NY 12228-0001

An on-site inspection follows to verify facility standards (heat, electricity, phone, desk, display space for retail dealers, proper signage, etc.).

Key Facility and Operating Requirements for Dealers

CR-78 and VS-142 require a physical New York place of business with:

Space to display at least three vehicles (retail dealers only).
Permanent signs meeting exact specifications (red background, white lettering, “REGISTERED MOTOR VEHICLE RETAIL DEALER” with facility number).
Secure storage for plates and forms.
A bound or approved computerized book of registry for all vehicles bought and sold.

Retail dealers must maintain the premises exclusively for their business (physical barriers required if other businesses share the location).

Dealer Plates, Temporary Registrations, and In-Transit Permits

CR-78 strictly regulates:

Dealer plates: Used only for demonstration, testing, or sale-related transport (maximum 5-day loan to customers; no personal or family use).
Temporary Certificates of Registration (MV-TCR): Retail dealers may issue 45-day temporary tags to buyers who provide proof of insurance.
Dealer-Issued Temporary Registration (under VTL §420-a): Qualified dealers can issue temporary registrations for inspected retail sales.

All plates and forms must be kept secure, and detailed records of issuance are mandatory. Lost or stolen plates require immediate police and DMV notification.

Recordkeeping, Certificates of Sale (MV-50), and VERIFI System

Dealers must maintain:

A daily bound registry (or DMV-approved computerized system) with full vehicle details, buyer/seller information, odometer readings, and MV-50 numbers.
Proof of ownership chain (titles, MCOs, bills of sale).
Odometer statements, warranty forms, and inspection records.

Electronic recordkeeping via the VERIFI system is encouraged (and required for many dealers) for faster title transfers. Small-volume dealers (<10 vehicles/year) may qualify for exemptions.

Certificates of Sale (MV-50) must be used consecutively and securely stored.

Advertising, Sales Away From Premises, and Consignment Rules

All advertising must include the dealer’s name, address, and facility number. Signs must be permanently displayed and visible from the street.

Sales away from the registered premises are limited (customer homes or up to two authorized off-site locations per year, with prior approval).

Consignment sales require a written agreement identifying the vehicle, price, and dealer authority. The dealer remains responsible for all transaction compliance.

Specific Rules for Transporters

Transporters must:

Provide a business justification for plates (e.g., factory-to-dealer transport).
Follow the same plate-use restrictions as dealers.
Maintain records of all vehicles transported.

Separate registration and plates are required — you cannot use dealer plates for transporter activities.

Penalties for Violating CR-78 Regulations

Violations of Part 78 or VTL §415 can result in:

Suspension or revocation of registration.
Civil penalties.
Denial of future applications.

Common issues include improper plate use, false advertising, inadequate records, or selling without proper registration.

How to Download the Official CR-78 PDF?

Download the complete, current CR-78 PDF directly from the New York DMV website:
https://dmv.ny.gov/forms/cr78.pdf

The file is large — the DMV recommends saving it to your local disk for easy reference. Always use the official link above for the most up-to-date version.

Frequently Asked Questions About CR-78

Do I need CR-78 if I only sell a few cars a year?
Yes — if you exceed five sales per year or display three or more vehicles, registration is required.

Can I operate without a physical dealership location?
No — a New York place of business is mandatory.

Are there special rules for new car franchise dealers?
Yes — they must submit franchise agreements and may qualify for provisional registration.

How often do I need to review CR-78?
Review it before any application, renewal, or major business change, and keep a copy at your dealership.

Stay Compliant with NY Dealer & Transporter Regulations

The CR-78 form is your complete roadmap to legal and successful operation as a New York motor vehicle dealer or transporter. By following these regulations, you protect your business, your customers, and your registration status.

For the latest guidance, visit the official NY DMV pages on opening a dealership or becoming a registered transporter, and always download the CR-78 PDF directly from dmv.ny.gov. If you have questions, contact the Office of Vehicle Safety at 518-474-0919.

Compliance starts with the right information — download CR-78 today and build your dealership on a solid regulatory foundation.