Ground it until the VIN is clear.

The Houck Safe Rental Car Act, in plain language

Named for sisters Raechel and Jacqueline Houck, the rule was enacted as part of the Fixing America’s Surface Transportation (FAST) Act of 2015.¹ The operative text is 49 U.S.C. § 30120(i):

• After the manufacturer notifies the rental company about a covered rental vehicle, you may rent it only if the defect or noncompliance is remedied before delivery — or a court has set aside the order.²
• Comply as soon as practicable, and no later than 24 hours after the earliest notice (including the VIN), by electronic means or first-class mail.²
• If the notice covers more than 5,000 vehicles in your fleet, the deadline is 48 hours.²
• If the remedy is not immediately available and the notice specifies temporary actions that eliminate the safety risk, you may rent (not sell or lease) after those actions are performed — then you must stop renting once the final remedy is available.²

A “rental company” under the Safety Act uses a fleet of 35 or more covered rental vehicles, on average, during the calendar year.³ Covered rental vehicles are generally 10,000 pounds GVWR or less, rented without a driver for an initial term under four months.⁴

Enforcement is real

On Oct. 16, 2023, NHTSA announced its first enforcement action against a rental company for renting vehicles with open, unrepaired recalls: a consent order with Zipcar that included a $300,000 civil penalty (half paid up front, half deferred).¹

NHTSA required Zipcar to audit open-recall vehicles, update employee training, and have outside counsel review written recall procedures.¹

Hertz and Avis have both flagged elevated vehicle recalls as an operating issue in 2026 earnings commentary — another reason VINs get pulled from the ready line even when the lot looks short.⁵