Vehicle Industry Registration Procedures Manual

The lienholder is not required to file a Certificate of Non-Operation (REG 102) (PDF) if the vehicle:

Was currently registered when the lien originated.
Subsequently expired while being stored by the lienholder pending a lien sale.
Fees (registration or PNO) are not due until the vehicle is sold at lien sale and must be paid within 20 days of sale to avoid penalties. A REG 102 is not required.
If the vehicle was not currently registered when the lien originated, all fees and penalties will be due when the vehicle is subsequently sold.

Chapter 18: Lien Sales – Abandoned – Abated Vehicles