North Carolina Code § 20-59

Unlawful for lienor who holds certificate of title not to surrender same when lien satisfied.
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It shall be unlawful and constitute a Class 3 misdemeanor for a lienor who holds a certificate of title as provided in this Article to refuse or fail to surrender such certificate of title to the person legally entitled thereto, when called upon by such person, within 10 days after his lien shall have been paid and satisfied.

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