Maryland MVA Clarifies Trade-In Valuation Standards During Dealer Audits

October 21, 2026

During a recent Dealer Forum, Maryland Motor Vehicle Administration (MVA) officials provided guidance on how trade-in values are evaluated during dealer audits. Under COMAR 11.15.33.05, MVA auditors may compare the trade-in allowance shown on a deal jacket against the Clean Trade-In value published by JD Power.

MVA noted that variances may be acceptable in a number of circumstances, including when additional equipment or products increase the vehicle’s value, when a customer is upside down on the trade-in, when the vehicle was subsequently sold for more than the JD Power value, or when the dealership relied on a different valuation guide. Dealers should be prepared to document and support these situations.

To help avoid audit issues, dealerships should retain copies of any alternative valuation source used to establish the trade-in value. If the vehicle was later sold for an amount exceeding the applicable JD Power value, dealers should also maintain the buyer’s order or other documentation supporting the higher valuation.

MVA further advised that if a trade-in value cannot be adequately supported and is determined to exceed the appropriate valuation, excise tax may be assessed on the difference between the dealer-assigned value and the JD Power valuation.

Dealers with questions about trade-in valuation practices or audit documentation are encouraged to contact WANADA. We are also happy to include this topic on the agenda for a future Dealer Forum discussion.