On April 23, 2018, the National Highway Traffic Safety Administration (“NHTSA”) opened Audit Query (AQ18002) to assess the timeliness and scope of four recalls filed by Daimler Trucks North America, LLC (“DTNA”). NHTSA subsequently expanded AQ18002 to examine the timeliness and scope of three additional DTNA recalls and compliance with early warning reporting and manufacturer communications reporting requirements. NHTSA and DTNA entered into a Consent Order on December 29, 2020, to resolve NHTSA’s assertions that certain recalls within the scope of AQ18002 were untimely, DTNA failed to timely submit certain manufacturer communications to NHTSA, and DTNA failed to submit field reports to NHTSA as required. As part of the Consent Order, DTNA agreed to a total civil penalty of thirty million dollars ($30,000,000), of which ten million dollars ($10,000,000) was paid on January 12, 2021. Also, of that total civil penalty, DTNA agreed to spend five million dollars ($5,000,000) on the specific performance obligations to develop advanced data analytics capabilities to enhance its ability to detect and study emerging safety-related defect trends on its vehicles (“Safety Data Analytics infrastructure”) and an advanced data analytics and reporting platform that integrates data on emerging safety-related defect trends on its vehicles and recall lessons learned (“Safety Communications Platform”). The Consent Order also held fifteen million dollars ($15,000,000) of the civil penalty in abeyance pending DTNA’s satisfactory completion of the requirements of the Consent Order, and its compliance with the Safety Act, and regulations thereunder. NHTSA and DTNA agreed to a two-year term for the Consent Order—with an option for NHTSA to extend the Consent Order for an additional year, if warranted. In the Consent Order, DTNA agreed to numerous performance obligations, including monthly meetings with NHTSA to discuss potential safety issues, recent manufacturer communications, and recall decisi