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I did this recently. He can just sell his car to a BMW dealership, problem solved. Yes, BMWFS has instituted a new rule and will no longer accept third party payoffs from non-BMW dealerships. AutoNation dealerships can still pay off the car because they own some BMW dealerships. As for those that are saying he should buy it out himself and then sell it: he would incur sales tax which might wipe out some or all of the potential profit. California allows sales tax to be waived if you sell the car within 10 days, but you first need to wait to receive the title, and then apply for a fresh title with BMWFS removed, and wait about a month for it to arrive in the mail.
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