N.Y. Veh. & Traf. Law § 2111

§ 2111. Refusing certificate of title. The commissioner shall refuse\nissuance of a certificate of title if any required fee is not paid or if\nhe has reasonable grounds to believe that:\n (a) The applicant is not the owner of the vehicle;\n (b) The application contains a false or fraudulent statement; or\n (c) The applicant fails to furnish required information or documents\nor any additional information the commissioner reasonably requires.\n