1. I/M Solutions Forum Session #7 Fraud Prevention & Detection Lewis Hays: Enforcement Unit Manager Stephen Leydon: Vehicle Testing Coordinator Georgia Department of Natural Resources 2012 I/M Solutions Trainig Forum1

2. GEORGIA ENFORCEMENT STAFF Civil - manager + 5 specialists 2 Criminal Investigators (not part of Civil Unit) 2012 IM Solutions Trainig Forum2

3. ENFORCEMENT STATISTICS CIVIL In 2011 -799 Notices of Violation issued -$23,775.00 collected in fines -67 inspector/station revocations -16 inspector/station suspensions 2012 IM Solutions Trainig Forum3

4. Fraudulent Testing Business Model Evolution A. Random Stations & inspectors Serving Mostly Individual Motorists, Some with Relatively High Volumes B. Criminal Enterprise (or network) I.Recruit Individual inspectors / Stations II.Set Up a Tennant Business in an Established Business (Garage / Shop) III.High Volume Fraud Station (Dummy Owner) In a Hard To View Location, ~100% Fraud 2012 IM Solutions Trainig Forum4

5. Fraudulent Testing Business Model Evolution (cont) IV. More Savvy in Which Vehicles They Test example: 1996 – 2000 only V. Connected To Car Lot(s), Tittle Pawn Shop(s), Auction House(s), or even Another Station VI. Communicate Large Number of VINs via Text Messaging, Fax, Or Other Electronic Means 2012 IM Solutions Trainig Forum5

6. Fraud Detection Detection includes software ◦Trigger Reports ◦Tailored Queries Detection includes overt audits Detection includes covert audits Detection includes complaints Detection includes tips Internal Communication 2012 IM Solutions Trainig Forum6

7. Fraud Detection (cont.) Triggers will provide overall view ◦Friendly Stations, Test Volume, Data Trends Queries vs. triggers ◦Set value vs. variable Queries provide a defined list vs. potential list ◦E-VIN mismatch Continues to Detect Lots of Violations, Especially From The Random Inspector/Station ◦E-Print Mismatch ; Currently Our Most Effective Method but Consumes the Most Time 2012 IM Solutions Trainig Forum7

8. Fraud Deterrence Locate inspector and/or station quickly Stations: Fine/Penalize Repeat Occurrences or Revoke Inspectors: Revoke Increased Criminal Enforcement Activities – Cooperative Efforts 2012 IM Solutions Trainig Forum8

9. Station Penalty Schedule 1st NOV2nd NOV3 rd NOV4th NOV Minor Administrative Warning Warning and Re ‑ training up to$400 30 days or up to $800 Major Administrative 30 days or up to $800 60 days or up to $1400 90 days or up to $3000 120 days or up to $6000 Minor Procedural Warning and Re ‑ training up to $400 30 days or up to $800 60 days or up to $1400 Major Procedural 60 days or up to $1400 90 days or up to $3000 120 days or up to $6000 Revocation Fraudulent (Owner not involved) NOV for failure to provide adequate oversight (plus copy of inspector’s NOV Re-training and 90 days or up to $5000 plus $250 per vehicle 180 days or up to $10,000 plus $500 per vehicle and Special Conditions Revocation Fraudulent - 1 vehicle or > (Owner involved) Revocation 2012 IM Solutions Trainig Forum9

10. Criminal Enforcement Efforts Coordination with Civil Unit Coordinate with Region 4 EPA/CID Coordinate with Local Enforcement Inspectors do NOT Pass Go, They Go Directly to Jail Seize Equipment and Misc Items Used In the Criminal Enterprise per Search Warrant 2012 IM Solutions Trainig Forum10

11. Fraud Prevention Prevention starts with software design Prevention includes hardware Prevention has a training component 2012 IM Solutions Trainig Forum11

12. Fraud Prevention(cont) State law, rules, and policies differ as to what will be allowed Software (OBD) can do a lot to filter potential fraudulent testing (especially CAN) Check for : power (B+), switched power RPM, loss of power (B+), verify communications protocol, VIN/E-VIN matching Program limits can play a part in limiting undesired practices Review of data on a regular basis assists in program (self) evaluation 2012 IM Solutions Trainig Forum12