In a letter dated October 16, 2012, BMW of North America, LLC (BMW) submitted a Defect Information Report (DIR), NHTSA Recall No. 12V-502 to NHTSA identifying a safety defect involving the possibility of unattended vehicle rollaway in MY 2005 through 2008 BMW 7-Series (approximately 45,000) vehicles equipped with the Comfort Access Option.The Comfort Access option allows the driver to start and stop the engine (by pressing the engine start / stop button) without inserting the key fob into the vehicles key slot in the instrument panel.Subject vehicles not equipped with the Comfort Access option require the key fob be inserted the key slot to start the engine.Upon removal of the key from the key slot the vehicle will automatically shift to Park if the driver has not done so using the gearshift lever.Sunject vehicles equipped with the Comfort Access option are designed such that when the vehicle is stopped with the service brakes applied and the transmission in Drive or Reverse, the driver can push the engine start/stop button one time, stopping the engine and automatically shifting the transmission to Park.In its DIR, BMW identified a condition such that if the driver depressed the start-stop button multiple times in rapid succession, the transmission could shift to Neutral instead of Park.With the transmission in neutral, depending on the slope of the road, the vehicle could rollaway if unattended.In review of data submitted to the Office of Defects Investigation (ODI) and of reports submitted to BMW, ODI identified 20 reports alleging vehicle rollaway involving vehicles equipped with Comfort Access.The vehicles identified in these reports are all subject to recall 12V-502.Ten of these reports were identified as likely related to the defect described in recall 12V-502.Two of the reports are likely related to other mechanical failures.The remaining 8 allegations of vehicle rollaway could not be associated with a specific cause.There are 32 reports alleging vehicle rollaway in the subject vehicles not equipped with the Comfort Access option.A vehicle based safety defect trend was not identified in these reports.Subject vehicles not equipped the Comfort Access option will automatically shift to Park once the key fob is removed from the key slot.In this regard these vehicles behave similarly to those with traditional mechanical keys where the key cannot be removed from the ignition unless the vehicle is shifted to Park.The difference between these vehicles and the subject vehicles with the Comfort Access option is that in the Comfort Access equipped vehicles, the engine can be started and stopped without the key fob in the key slot.ODI reports 10429922 and 10419177 noted in the EA opening resume were determined to be vehicles not equipped with the Comfort Access option and ODI did not identify a vehicle based safety defect associated with these incidents.This investigation is closed.The ODI report cited above can be reviewed at www-odi.nhtsa.dot.gov/owners/SearchNHTSAID under the following identification (ODI) numbers:10185770
