The Wisconsin MV2115 form, officially the Reassignment Supplement to Certificate of Title, lets a licensed Wisconsin dealer, wholesaler, auction dealer, or salvage dealer reassign a vehicle to another licensed dealer or wholesaler when a nonconforming certificate of title has no reassignment spaces left. It is a narrow document. It applies only to nonconforming titles (ones whose odometer-disclosure format does not meet current federal standards), only when the title’s reassignment spaces are already used up, and only for transfers between licensees, never for a sale to a retail customer.
When the MV2115 Is the Right Form
Three conditions have to line up before you reach for an MV2115:
- The vehicle is titled on a nonconforming certificate of title.
- Every reassignment space on that title is already filled.
- The transfer is to another licensed dealer, wholesaler, auction dealer, or salvage dealer.
Wisconsin Administrative Code Trans 154.03(3)(d)3 is the governing rule. When a nonconforming title has no available reassignment spaces, the reassignment and odometer disclosure “shall be completed on a conforming statement which has been issued or approved by the department.”1Wisconsin State Legislature. Wisconsin Administrative Code Trans 154.03 – Odometer Disclosure Requirements The MV2115 is the department-approved form that fills that role. Once completed, it attaches to the original title and travels with it through every later transfer.
The same rule applies if a nonconforming title still carries a conforming odometer-disclosure statement but has no reassignment spaces left. The reassignment and odometer disclosure go on the MV2115 or another conforming document the department has approved.1Wisconsin State Legislature. Wisconsin Administrative Code Trans 154.03 – Odometer Disclosure Requirements
When the MV2115 Does Not Apply
If the title is conforming and the reassignment spaces are full, the MV2115 is not an option. Wisconsin Statute 342.16(1)(d) requires that a dealer or wholesaler in that situation “shall make application for a certificate of title naming the dealer or wholesaler as owner of the vehicle.”2Wisconsin State Legislature. Wisconsin Statutes Section 342.16 – Transfer to or From Dealer You title the car in the dealership’s name before you can resell it.
The form is also off-limits for retail sales. It covers transfers between licensees. A sale to an individual buyer uses the standard title-and-registration application, not the MV2115.
Before filling anything in, confirm the title in your hands is actually nonconforming. Using the wrong form for the title type gets the transaction rejected at the DMV counter.
Filling Out the Form
Use permanent black or blue ink. No pencil, no whiteout, no corrections. The form captures the same information as a title’s reassignment block, formatted to meet current federal odometer-disclosure standards.
Vehicle Information
Enter the full 17-character VIN. Copy it from the original title and verify it against the VIN plate on the vehicle itself, usually visible through the base of the windshield on the driver’s side or on the federal certification label inside the driver’s door jamb. One wrong character causes a rejection. Record the year, make, model, and body type exactly as they appear on the existing title.
Dealer and Buyer Information
Enter your dealership’s legal business name as it appears on your Wisconsin dealer license, with your dealer license number. The buying dealer’s or wholesaler’s legal name, license number, and business address go in the buyer fields. The buyer must be a licensed entity, not an individual consumer.
Odometer Disclosure
This is the section that creates the most legal exposure if handled carelessly. Record the exact mileage on the odometer at the time of transfer. Do not round. Wisconsin Statute 342.155 requires the transferor to certify one, and only one, of three statements:3Wisconsin State Legislature. Wisconsin Statutes Section 342-155 – Mileage Disclosure Requirements of Transferors and Transferees
- Actual mileage.
- Mileage in excess of the odometer’s mechanical limit (the odometer has rolled over).
- Not actual mileage, where a discrepancy exists because of a broken odometer, replaced cluster, or unknown history.
Check one box only. Both the selling dealer’s authorized representative and the buying dealer’s representative must sign and date the disclosure. The buyer prints their name, and the seller keeps a copy.3Wisconsin State Legislature. Wisconsin Statutes Section 342-155 – Mileage Disclosure Requirements of Transferors and Transferees
Penalties for Odometer Disclosure Violations
A violation of Wisconsin’s mileage-disclosure rules can bring a forfeiture of up to $1,000. If the violation involves intent to defraud, it rises to a Class H felony.3Wisconsin State Legislature. Wisconsin Statutes Section 342-155 – Mileage Disclosure Requirements of Transferors and Transferees
Federal penalties stack on top. Under 49 U.S.C. 32709, a civil penalty of up to $10,000 per vehicle applies, capped at $1,000,000 for a related series of violations. Knowingly and willfully tampering with an odometer or making a false disclosure can bring up to three years in federal prison.4Office of the Law Revision Counsel. 49 USC 32709 – Penalties Because the penalties are per vehicle, exposure compounds quickly across a lot.
What to Do With the Completed Form
Staple the signed MV2115 to the back of the original nonconforming certificate of title. The two documents move together as one package through every subsequent transfer. If they get separated, the chain of title breaks, and the retail buyer at the end of the chain will have problems applying for a Wisconsin title.
Hand the stapled package to the purchasing dealer. When a dealer in the chain eventually sells to a retail customer, that dealer submits the original title with all attached reassignment supplements, along with a completed application for title and registration, to the Division of Motor Vehicles. Wisconsin Statute 342.16(1)(a) requires dealers to process and deliver the title application and supporting materials to the department within seven business days of the sale, plus one additional business day for mailing.2Wisconsin State Legislature. Wisconsin Statutes Section 342.16 – Transfer to or From Dealer
Dealers who do not process their own title transactions pay the department a $15 processing fee per transaction.5Wisconsin State Legislature. Wisconsin Administrative Code Trans 141.05 – Dealer Title Processing Fees
Where to Get the Form
Wisconsin requires original, serialized MV2115 forms. Photocopies and scans are not valid. You can order forms from the Wisconsin Department of Transportation or through approved third-party vendors such as the Wisconsin Automobile and Truck Dealers Association. The DOT keeps the full list of dealer forms and publications on its website.6Wisconsin Department of Transportation. Dealer Forms and Publications Keep a supply on hand. Running out mid-deal means waiting on originals before anything else moves.
Record-Keeping
Wisconsin Administrative Code Trans 138.04 sets the books and records that licensed dealers and used-vehicle wholesalers must keep at their licensed premises.7Cornell Law Institute. Wisconsin Code Trans 138-04 – Records Kept A copy of every completed dealer reassignment form belongs in your permanent files. Used-vehicle transaction records, including reassignment documentation, must be retained for five years and kept accessible for inspection during DOT audits. State investigators cross-check mileage disclosures against previous title assignments in the central database, so gaps in your paperwork tend to surface during an audit.
Mistakes That Cause Rejection
Most MV2115 rejections trace back to a short list of avoidable errors:
- Using the form on a conforming title, or for a retail sale, when it is restricted to dealer-to-dealer transfers of nonconforming titles.
- Transcribing the VIN incorrectly from the title or failing to verify it against the vehicle.
- Rounding the odometer reading, leaving it blank, or checking more than one disclosure category.
- Missing a signature. An unsigned odometer disclosure is incomplete under both state and federal law.8Office of the Law Revision Counsel. 49 USC 32705 – Disclosure Requirements on Odometers
Check the title type first, verify the VIN twice, record the mileage exactly as it reads, and confirm both representatives have signed and dated the disclosure before the package leaves your desk.