Engine Control Module (ECM) Reprogramming (WQW-58R)

ENGINE CONTROL MODULE (ECM) REPROGRAMMING

SERVICE CAMPAIGN BULLETIN

APPLICABILITY

2015 MY WRX 2.0L DIT Models 2014-2015 MY Forester 2.0L DIT Models

INTRODUCTION

Subaru of America, Inc. has determined that vehicles affected by this Service Program require ECM reprogramming.

This bulletin includes the service procedure for diagnosis and repair of customer concerns involving engine idle roughness or, in some cases, engine noise and/or damage resulting from spark knock (pre-ignition). The Engine Control Module logic has also been optimized requiring the ECM reprogramming.

The new logic optimizes the ECM for control of the following parameters:

• Change to Fuel Cut control when fuel level is extremely low/near empty
• Change to improve idle smoothness/quality
• Change to boost pressure control under wide-open throttle (WOT) conditions.

Under certain high engine load driving conditions, spark knock can occur which results in elevated cylinder temperatures and pressures. Over time, excessive erosion of the spark plugs and possible damage to the pistons can be consequences of continued operation with these conditions present.

AFFECTED VEHICLES

• Certain 2015 model year WRX 2.0L DIT (Direct Injection Turbo) vehicles
• Certain 2014-2015 model year Forester 2.0L DIT vehicles

Not all vehicles listed below are covered by this service program. Coverage for all affected vehicles must be confirmed by using the Vehicle Coverage Inquiry function on subarunet.com. This data is scheduled to be available in the system when owner notification begins.

MODEL YEAR	MODEL	STARTING PRODUCTION DATE	ENDING PRODUCTION DATE
2015	WRX 2.0L DIT	January 17, 2014	September 26, 2014
2014 & 2015	Forester 2.0L DIT	January 15, 2013	November 4, 2014

OWNER NOTIFICATION

Notification letters will be sent by First Class mail to owners of all potentially affected vehicles in early February, 2016. A copy of the letter is included at the end of this bulletin.

RETAILER AFFECTED VIN LISTS

Each Subaru retailer will receive an affected VIN list from their Zone Office when owner notification begins. Vehicles will be assigned to retailers in the affected VIN list as follows:

• Original vehicle owners are assigned to the original selling retailer when their current address is within a 100 mile radius of that retailer.
• If the original selling retailer is inactive, the VIN has been assigned to the nearest active retailer.
• For any new owners or when original owners live more than 100 miles from the original selling retailer, the VIN has been assigned to the nearest active retailer.

SUBARU RETAILER PROGRAM RESPONSIBILITY

Retailers are to promptly perform the applicable service procedures to correct all affected vehicles in their inventory. Additionally, whenever a vehicle subject to this service program is taken into inventory or in for service, necessary steps should be taken to ensure the Service Program has been performed before selling or releasing the vehicle.

Any vehicles listed in a Service Program that are in the retailer's stock must be:

• Immediately identified
• Tagged or otherwise marked to prevent their delivery or use prior to inspection and/or repair
• Repaired in accordance with the repair procedures outlined in this Service Program bulletin.

PACK FILE APPLICABILITY

MODEL/MODEL YEAR		TRANSMISSION	PAK FILE NAME	NEW ECM PART NUMBER	OLD ECM PART NUMBERS	NEW CID NUMBER
2015MY WRX 2.0L		MT	22765AG235.pak	22765AG235	22765AG230, 31, 32, 33 & 34	LF75300S
		CVT	22765AG245.pak	22765AG245	22765AG240, 41, 42, 43 & 44	LF75300T
Forester Turbo	2014	CVT	22611AW068.pak	22611AW068	22611AW060, 61, 62, 63, 64, 65, 66 & 67	AF56D00B
	2015		22765AG974.pak	22765AG974	22765AG970, 71, 72 & 73	LF61700B(1)
(1) When searching Flashwrite for a 2015 Forester Turbo by Vehicle spec, the New CID will display incorrectly although the correct (new) update will be applied (LF61700B) as long as the January, 2016 SSM4 software release is being used. This will be corrected in a future SSM4 release.

MODIFIED VEHICLES

Aftermarket Engine Control Module (ECM) software changes may adversely affect the proper operation of some vehicles and prevent Subaru retailers from performing the ECM software logic update described in the WQW-58 customer letter. If unable to perform this update as a result of non-authorized modifications made to the vehicle's ECM, the vehicle must be returned to its original factory condition at the Owner's expense. In this case, the Owner must be informed of their options to return the ECM to original condition by one of the following methods:

• Owner removes non-authorized ECM modifications returning ECM to original condition
• Owner installs the original ECM
• Owner requests retailer install the original ECM (at vehicle Owner's expense)
• Owner installs a new factory ECM
• Owner requests retailer install a new factory ECM (at vehicle Owner's expense).

If aftermarket engine modifications are preventing completion of the engine inspection or repair procedures outlined in this service campaign, the customer must be informed of their options to:

• Owner removes the aftermarket engine modifications
• Owner requests the retailer remove the aftermarket modifications (at vehicle owner expense).

If any of the following conditions exist, the retailer must complete the Vehicle Modification and Accident Damage Form as found on Subarunet under Service/Forms.

• Owner declines to return the ECM to original factory condition, ECM modifications are preventing installation of required software update.
• Owner declines to remove the aftermarket engine modifications, Engine modifications are preventing completion of the engine testing or repair.
• Retailer determines the procedure cannot be performed with existing modifications. Engine or ECM modifications are preventing the retailer from completing some portion of the campaign procedures.

All completed Vehicle Modification and Accident Damage Forms must be forwarded to Claimsteam@subaru.com.  A list of modifications and photos must be included. These forms will be used to document the condition(s) preventing the completion of this campaign and will be noted on the Coverage Inquiry Report located on subarunet.com/Service-Claims Entry/Info/Vehicle Inquiry (combined).

In addition, the following language must be noted on the Repair Order:

"Aftermarket Engine Control Module (ECM) software changes and/or aftermarket engine modifications are preventing completion of the service campaign described in the WQW-58 customer notification letter. Your Subaru retailer is unable to perform this update as a result of non-authorized modifications made to your vehicle's ECM or engine. Subaru will not be able to assist you until your vehicle is returned to its original factory condition. If this software update is not performed or if the installed aftermarket modifications cause similar engine damage as addressed in this Service Program, Subaru may not assist with any resulting repairs to the vehicle."

Follow the procedure steps below when a potentially affected vehicle presents for repair. Perform a Vehicle Inquiry before proceeding to Step 1  .

Step 1:  Is WQW-58 open?

YES:  Check the current CID of the ECM using SSM4. Refer to the above Pack File Applicability table and proceed to Step 2  .

NO: STOP.  Do not proceed any further with this procedure. Diagnose any Customer concerns following normal troubleshooting procedures using the applicable Service Manual.

Step 2:  Are there any DTCs (other than misfire related DTCs) stored in memory?

YES:  Diagnose and repair as per the stored DTC(s) using the applicable Service Manual. When completed, proceed to Step 3  .

NO:  Proceed to Step 3  .

Step 3:  Reprogram the ECM following the currently established normal procedure. When complete, verify the "after" CID to comfirm successful reprogramming and record it on the repair order hard copy.

Step 4:  Remove and inspect the spark plugs closely for any damage, erosion or melting. Inspect, rotate, turn upside-down and shake each spark plug to check for a cracked or loose porcelain insulator around the center electrode. Take note which cylinder(s) have spark plugs with verified damage and mark each plug, damaged or not, with the corresponding cylinder number.

Step 5:  Perform a cylinder leak-down test on ALL 4  cylinders following the procedures supplied with the testing equipment being used. Record test results on the Repair Order hard copy. Due to differences in leak-down test equipment, an actual cylinder leakage specification cannot be provided. However, your results should be consistent from cylinder to cylinder. Large variations in cylinder leakage readings will direct you toward a problem cylinder. Experience with the test equipment being used and past engine failure diagnosis should be your guides for how much variation between cylinders is acceptable when damage has occurred to one or more cylinders. Contact your FSE or Techline to review if you are uncertain about your test results.

Evaluation of Test Results 

• If the inspections performed in Step 4  above revealed spark plug damage, the engine assembly must be replaced (refer to Part 3 of Flow Chart) following the procedure in the applicable Service Manual.
• If no spark plug damage is found but high or inconsistent leak-down results are determined, reinstall the plugs and proceed to Step 6  .
• If the testing performed in Step 5 above revealed high cylinder leak down percentages as described in the test equipment instructions or inconsistencies between cylinders, use the table below as a guide to help determine where the compressed air is being lost. If it is determined the compressed air is leaking into the exhaust, or intake (heard escaping from the tail pipe or, throttle body), this would likely indicate a valve sealing concern. Proceed to Step 6.  If it is determined the compressed air is leaking into the crankcase (heard escaping from the oil fill pipe and/or dipstick tube), proceed to Step 6  .

Step 6:  Perform a top engine clean using SOA868V9160 Top Engine Cleaner and companion tool #SOA868V9430. When completed, road test the vehicle then perform Step 5  again and re-evaluate the results. If the results are now consistent between cylinders, the leakage was not a result of any mechanical concern. Reinstall the spark plugs to complete the procedure. If there is still significant or unusual leakage past the intake and/or exhaust valves, it is not related to this campaign. Diagnose and repair the engine following the procedures in the applicable Service Manual. If there is still significant or unusual leakage into the crankcase, proceed with replacing the engine assembly (refer to Part 3 of Flow Chart).

Source of Compressed Air Loss:	Probable Cause:
Throttle Body	Intake Valve(s) Sealing (1)
Exhaust (Tail Pipe)	Exhaust Valve(s) Sealing (1)
Crankcase (Oil Fill/Dipstick Tube)	Piston Ring Sealing/Possible Ring Land(s) Damage
(1) This finding is not related to the condition(s) addressed by this bulletin. Engine replacement is not required.

When diagnosis and/or leak-down testing has confirmed either spark plug damage and/or cylinder leakage into the crankcase, install a complete engine assembly (if available) following the procedure in the applicable Service Manual (refer to Part 3 of the Flow Chart). If a complete engine assembly is not available (and will be on backorder for 7 days or more), a new short block assembly must be used for the repair along with replacing the affected cylinder head (or heads) as required and described below.

"APPENDIX A" IMPORTANT INFORMATION REGARDING RETROFITTING THE P.N. 10100CC130 ENGINE ASSEMBLY TO 2014-15MY FORESTER TURBO

WQW-58 Engine Assembly "Retrofit" Parts List 

Part Number:	Description:	Quantity:
11821AA660	CONN PCV	1
11849AA160	PIPE ASSY - PCV	1
99081AA370	HOSE COMPL - VACUUM	1
13144AA200	GUIDE - CHAIN	1
805915040	HOSE CLP - 15	1
99081AA370	HOSE CP - VACUUM	1
805918010	HOSE CLAMP	5
O92315002		1
13320AA021	SPKT AY CMS, INT RH	1
13321AA011	SPKT AY CMS, EXH RH	1
13322AA031	SPKT AY CMS, INT LH	1
13323AA011	SPKT AY CMS, EXH RH	1
22318AA060	PIPE - VAC	1
909205046	CLIP	1
22433AA691	COIL ASSY - IGN	4
24020AF363	HARN - ENG	1
14738AA130	GSKT - EGR PIPE	1
14738AA170		1
14035AA620	GSKT - INTAKE MAN	8
15090KA000	O-RING - OIL LEVEL	1
806939060	O-RING	1
806912190		3
806924120		1
806916080		1
806750080	OIL SEAL	1
14038AA040	GSKT - EXHAUST MAN	2
44011AG000	GSKT - EXH PIPE REAR	1
14497AA030	GSKT - AIR INT DUCT	1
17556AA000	GSKT - UNION BANJO	2

Additional Tips: 

• When installing the new engine harness assembly:
  • Use caution when removing the foam insulators from the high-pressure fuel piping.
  • The EGR assembly does not  have to be removed as the new harness can CAREFULLY  be fed under the large EGR pipe as shown in the photos below.
• After removing the "old" timing chain guide and sprockets, mark them accordingly so they do not get confused with the new replacement parts.
• Always confirm the reluctor between the flex plate and crankshaft flange on the new engine matches the original BEFORE reinstalling the assembly.
• Confirm the new engine assembly has both alignment dowels installed (and none in the transmission).

Step 7:  When the required repairs are complete, confirm the running condition of the engine. If the engine runs normally, no further action is required. Affix the campaign sticker to the radiator support and release the vehicle.

• If the GR8 indicates the vehicle's battery must be charged, charge the battery using the GR8 before proceeding to reprogram the vehicle while using the Power Supply Mode.
• Control module failures as a result of battery discharge during reprogramming are not a matter for warranty. Should any DTCs reset after the reprogramming update is performed, diagnose per the procedure outlined in the applicable Service Manual.

STATE EMISSION TESTING ADVISORY

After ECM reprogramming, the OBD system's readiness code monitors will reset to "incomplete". Normally, the vehicle needs to be driven under a variety of conditions before the readiness code monitors will indicate "complete". (See State I/M Program Advisory Bulletin number 11-120-12R, dated 2-02-2016 for details.)

SERVICE PROGRAM IDENTIFICATION LABEL

Type or print the necessary information on a Service Program identification label.  The completed label should be attached to the vehicle's upper radiator support.

Additional labels are available through normal parts ordering channels. The part number is MSA6P1302. Ordering qty 1 = 1 sheet of 20 labels.

PART NUMBER	APPLICABILITY	DESCRIPTION	ORDER QUANTITY
MSA6P1302	All models	Campaign Completion Labels (contains one sheet of 20 labels)	1

CALIFORNIA "VEHICLE EMISSION RECALL - PROOF OF CORRECTION" CERTIFICATE

The California Air Resources Board and the Department of Motor Vehicles Registration/Recall Program requires that all emission related Recall/Campaign or Service Program repairs be completed before a vehicle registration is renewed. Please provide owners of vehicles registered in the state of California a completed "Vehicle Emission Recall - Proof of Correction" certificate. Vehicle owners should be advised to retain this certificate because the California Department of Motor Vehicles may require they provide proof this service program repair has been completed.

Additional certificates are available through normal parts ordering channels using part number MSA6P1301. Quantity 1 = 1 booklet of 50 certificates.

CLAIM REIMBURSEMENT AND ENTRY PROCEDURES

Credit to perform this service program will be based on the submission of properly completed repair order information. Retailers may submit claims through subarunet.com. Enter the Recall Claim the same day as the recall is performed to update the recall status to "Completed".

VEHICLES WITH MODIFICATIONS
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR TIME	CLAIM TYPE	CAMPAIGN CODE
Campaign incomplete due to modifications	MODIFIED VEHICLE CID AND CVN CHECKS	B114-660	0.4	PA	BAX-58
	MODIFIED VEHICLE ENGINE CHECKS	C114-661	0.4
ECM/Engine Inspection ONLY, NO Repairs Made.
WQW-58 SERVICE PROGRAM WITH NO ENGINE OR PART REPLACEMENT
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR TIME	CLAIM TYPE	CAMPAIGN CODE
Spark Plugs - OK Leak-Down Test - OK ECM is up-to-date(1)	INCLUDES: CID CHECK, SPARK PLUG REMOVAL FOR INSPECTION, MARKING, REINSTALLATION, CYLINDER LEAK-DOWN TEST, ECM CHECK FOR REPROGRAMMING	B114-550(1)	3.3	RC	WQW-58
Spark Plugs - OK Leak-Down Test - N/G ECM is up-to-date(1)	INCLUDES: CID CHECK, SPARK PLUG REMOVAL FOR INSPECTION, MARKING, REINSTALLATION, CYLINDER LEAK DOWN TEST, ECM CHECK FOR REPROGRAMMING	B114-666(1)	3.3
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR IME	CLAIM TYPE	CAMPAIGN CODE
Top Engine Clean	HIGH FIRST LEAK-DOWN TEST RESULT, PERFORM TOP ENGINE CLEAN, ROAD TEST & PERFORM 2ND LEAK-DOWN TEST	C114-663	2.2	RC	WQW-58
If ECM is not up-to-date	ECM REPROGRAMMING	C114-558	0.3
Top Engine Cleaner Corrected Cylinder Leakage Condition.
(1) If ECM reprogramming is required, use in conjunction with C114-558

COMPLETE ENGINE ASSEMBLY REPLACEMENT
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR IME	CLAIM TYPE	CAMPAIGN CODE
Spark Plugs - and/or Leak-Down Test - N/G ECM up-to-date(2)	INCLUDES: CID CHECK, SPARK PLUG REMOVAL FOR INSPECTION, MARKING, REINSTALLATION, LEAK-DOWN TEST, ENGINE REPLACEMENT AND ECM CHECK FOR REPROGRAMMING	B114-662(2)	7.6	RC	WQW-58
Top Engine Clean (if required)(1)	HIGH FIRST LEAK-DOWN TEST RESULT, PERFORM TOP ENGINE CLEAN, ROAD TEST & PERFORM 2ND LEAK-DOWN TEST	C114-663	2.2
When Applicable	ENGINE HARNESS CHANGEOVER TO REPLACEMENT ENGINE ASSEMBLY WHEN REQUIRED ON APPLICABLE FORESTER MODELS	C114-556	1.9
If ECM is not up-to-date	ECM REPROGRAMMING	C114-558	0.3
SHORT BLOCK REPLACEMENT FOR WHEN COMPLETE ENGINE ASSEMBLY IS NOT AVAILABLE
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR IME	CLAIM TYPE	CAMPAIGN CODE
Spark Plugs - and/or Leak-Down Test - N/G ECM up-to-date(2)	INCLUDES: CID CHECK, SPARK PLUG REMOVAL FOR INSPECTION, MARKING & REINSTALLATION, LEAK DOWN TEST AND ECM CHECK FOR REPROGRAMMING	B114-664(2)	3.3	RC	WQW-58
Top Engine Clean (if required)(1)	HIGH FIRST LEAK-DOWN TEST RESULT, PERFORM TOP ENGINE CLEAN, ROAD TEST & PERFORM 2ND LEAK-DOWN TEST	C114-663	2.2
Spark Plugs - and/or Leak-Down Test - N/G Only one bank affected	SHORT BLOCK AND ONE COMPLETE CYLINDER HEAD ASSEMBLY REPLACED	C114-551	11.8
Spark Plugs - and/or Leak-Down Test - N/G Both banks affected	SHORT BLOCK AND BOTH COMPLETE CYLINDER HEAD ASSEMBLIES REPLACED	C114-554	12.2
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR IME	CLAIM TYPE	CAMPAIGN CODE
Includes time for changeover of all cylinder head components including valve replacement when required	SHORT BLOCK AND ONE BARE CYLINDER HEAD REPLACED	C114-571	13.4	RC	WQW-58
	SHORT BLOCK AND BOTH BARE CYLINDER HEADS REPLACED	C114-574	14.6
If ECM is not up-to-date	ECM REPROGRAMMING	C114-558	0.3
NOTE: (1) Top Engine Cleaning is Not Required if Spark Plug damage is confirmed. Failed Leak-Down Testing, Top Engine Cleaner Did Not Correct Cylinder Leakage Condition.  (2) If ECM reprogramming is required, use in conjunction with C114-558

POST-REPAIR CONCERN
OUTCOME	LABOR DESCRIPTION	LABOR OPERATION #	LABOR IME	CLAIM TYPE	CAMPAIGN CODE
Spark Plugs - OK Leak-Down Test - OK ECM Reprogramming BUT engine operation issue(s) persist	INCLUDES: CID CHECK, SPARK PLUG REMOVAL FOR INSPECTION, MARKING, REINSTALLATION, LEAK-DOWN TEST, ECM REPROGRAMMING AND DATA FILE COLLECTION FOR SUBMISSION TO TECHLINE	B114-553	3.9	WC	BAY-58
Condition Occurred After Engine Repairs/Replacement Completed. MUST Review With Techline And/Or FSE Before Proceeding!

ADDITIONAL REQUIRED CLAIM CODING FOR USE WITH "APPENDIX A": 

Labor Description	Labor Operation #	Labor Time	Fail Code	NOTE:
RETROFIT 2017MY COMPLETE ENGINE ASSY. FOR USE IN PRIOR MY VEHICLE	C114-557	5.7	WQW-58	Must be used with B114-662
RETROFIT 2017MY SHORT BLOCK ASSY. FOR USE IN PRIOR MY VEHICLE	C114-559	1.5		Must be used with B114-664

IMPORTANT REMINDERS: 

• SOA strongly discourages the printing and/or local storage of service information as previously released information and electronic publications may be updated at any time.
• Always check for any open recalls or campaigns anytime a vehicle is in for servicing.
• Always refer to STIS for the latest service information before performing any repairs.

OWNER NOTIFICATION LETTER

Subaru of America, Inc 

Subaru Plaza

PO Box 6000

Cherry Hill, NJ 08034-6000

800-782-2783

www.subaru.com

Subaru Service Program WQW-58 

February 2016 

Dear Subaru Owner: 

We would like to thank you for your selection of a Subaru vehicle. We take pride in our products and are committed to your continued satisfaction.

Subaru has developed a modification to the Engine Control Module (ECM) software logic due to a possible pre-ignition issue on certain 2015 model year WRX vehicles and certain 2014 and 2015 model year 2.0XT Forester vehicles, equipped with a 2.0 liter turbocharged engine.

You received this notice because our records indicate that you currently own one of these vehicles.

DESCRIPTION 

Under certain high engine load driving conditions, engine combustion may occur prior to spark ignition resulting in elevated cylinder temperatures and pressures. This could cause a rough idle and engine noise, and if left unaddressed it could lead to excessive erosion of the spark plugs and possible engine damage.

REPAIR 

The repair will be performed at no cost to you. Subaru will inspect your vehicle and reprogram the ECM. If any related spark plug or engine damage is detected during the inspection, your vehicle will be repaired.

WHAT YOU SHOULD DO 

You should immediately contact your Subaru retailer (dealer) for an appointment to have this repair performed.

HOW LONG WILL THE REPAIR TAKE? 

The time to perform the inspection and reprogramming is approximately three hours. However, it may be necessary to leave your vehicle for a longer period of time on the day of your scheduled appointment to allow your Subaru retailer flexibility in scheduling, or for repair.

CALIFORNIA REGISTERED OWNERS 

The California Air Resources Board requires that emission related campaigns be completed prior to California's vehicle registration renewal process; without this repair, you will not be able to register your vehicle during your next annual registration. Upon completion of this campaign, your California dealer will complete and provide you a "Proof of Correction Certificate." If required, present the certificate to the California Department of Motor Vehicles (the "DMV") when renewing your California registration as proof of campaign completion. If the DMV does not request the certificate, we recommend that you keep it for your records.

In addition, the State of California requires that every vehicle must pass an emission test (SMOG Check) every two years and before it is sold. Without the service we are providing at no charge, your vehicle may not pass this test.

CHANGED YOUR ADDRESS OR SOLD YOUR SUBARU? 

If you have moved or sold your vehicle, please complete the enclosed prepaid postcard and mail it to us. Or if you prefer to update this information online, please go to www.subaru.com, select 'Customer Support,' then select 'Address Update' or 'Ownership Update' from the drop down menu.

IF YOU NEED FURTHER ASSISTANCE: 

To locate the nearest Subaru retailer you can access our website at www.subaru.com and select 'Find a Retailer.'

For additional information, please go to: http://www.wqw58.service-campaign.com.

If you need additional assistance, please contact us directly:

• By e-mail: Go to www.subaru.com, Customer Support and select "Contact Us"
• By telephone: 1-800-SUBARU3 (1-800-782-2783)

  Monday through Thursday between 7:30 a.m. and 8:00 p.m. ET

  Friday between 10:30 a.m. and 5:00 p.m. ET

  Saturday between 9:00 a.m. and 3:30 p.m. ET

• By U.S. Postal mail: Write us at Subaru of America, Inc., Attn: Customer-Retailer Services Department, P.O. Box 6000, Cherry Hill, NJ 08034-6000

Please contact us immediately if the Subaru retailer fails or is unable to make the necessary repairs free of charge.

Your continued satisfaction with your Subaru is important to us. Please understand that we have taken this action in the interest of your vehicle's proper operation. We sincerely apologize for any inconvenience this matter may cause and urge you to schedule an appointment as soon as possible to have this repair performed.

Sincerely,

Subaru of America, Inc.

Notice to Lessors: Under Federal law the lessor of a vehicle who receives this letter must provide a copy of it to the vehicle lessee(s) within 10 business days from receipt. The lessor must also keep a record of the lessee(s) to whom this letter is sent, the date sent, and the applicable vehicle identification number (VIN). (For the purposes of this section, a lessor means a person or entity that in the last twelve months prior to the date of this notification has been the owner, as referenced on the vehicle's title, of any five or more leased vehicles. A leased vehicle is a vehicle leased to another person for a term of at least four months.) 

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