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I agree with Dackelone; if I was BMWNA, I would expect the dealers to have their cars fixed first, specifically to get their pool ready for the tsunami of 1,900,000 cars that is about to come through the service network. End of discussion.
As to the idea that dealers are in charge of the VINs and priority, I doubt it. They may be able to determine a list of VINs at the beginning, but very shortly BMWNA is going to be driving the whole thing with parts availability by VIN, and customer notifications by mail. NHTSA has ordered it.
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