Investor's Corner
Tesla’s Model 3 safety claims and the NHTSA’s scrutiny: A look at an old (revived) story
Multiple reports have recently emerged about the US National Highway Traffic Administration scrutinizing Tesla and the company’s claims that the Model 3 has the lowest probability of injury among vehicles tested by the agency. It should be noted that the NHTSA’s scrutiny, which involved a cease-and-desist letter to Tesla and a prompt response from the automaker, transpired last October, following the agency’s release of the Model 3’s 5-Star Safety Rating.
The NHTSA’s reaction to Tesla recently came to fore due to documents shared by staunch TSLA critic and transparency group Plainsite, which was able to access both the NHTSA’s cease-and-desist letter to Tesla as well as the electric car maker’s response to the agency thanks to a Freedom of Information Act request. What’s quite peculiar about the new string of reports, including those from Bloomberg and Reuters, is that they highlight the NHTSA’s allegations about the company’s alleged misleading claims about the Model 3, but not Tesla’s response arguing that it used the agency’s own data to arrive at its conclusions.
To get an accurate picture of this story, one must look at the full cease-and-desist letter sent by the NHTSA to Tesla, as well as the entire contents of the electric car maker’s response. A copy of each letter will be embedded in this article, to provide a full account of the two parties’ correspondence.
Following Tesla’s release of its blog post stating that the Model 3 has the lowest probability of injury among the vehicles tested by the NHTSA, the agency sent the Silicon Valley-based company a cease-and-desist letter. Addressed to Elon Musk, the letter claimed that Tesla had “issued a number of misleading statements regarding the recent Government 5-Star Ratings of the Tesla Model 3.” NHTSA Chief Counsel Jonathan Morrison, who sent the letter, further argued that statements such as “lowest probability of injury in all cars” are inaccurate and not in the best interests of consumers.
The NHSTA’s cease-and-desist letter to Tesla could be accessed below.
Tesla Model 3 Safety Claims… by Simon Alvarez on Scribd
Tesla disagreed with the NHTSA’s allegations in its response to the cease-and-desist letter. The electric car maker argued that its statements about the Model 3’s safety were neither untrue nor misleading, especially since the company used the NHTSA’s own data (which could be accessed here) when it stated that the electric sedan, as well as its largest siblings, the Model S and Model X, have the lowest probability of injury among vehicles tested by the agency. Tesla also noted that the Model 3’s achievement is “exactly what NHTSA intended with the NCAP — to encourage manufacturers to continuously immprove safety.” With this in mind, Tesla noted that there was no reason to discontinue its blog post highlighting the Model 3’s safety.
Tesla’s full response to the NHTSA could be read below.
Tesla Model 3 Safety Claims… by Simon Alvarez on Scribd
It should be noted that the NHTSA has not doubled down on its allgetations against Tesla’s statements about the Model 3. The electric car maker’s blog post explaining the Model 3’s stellar safety scores is still active today. Contrary to Plainsite’s statements that Tesla was “referred to the FTC for repeatedly lying about the safety of their vehicles,” it appears that the NHTSA opted to back down from its allegations once the electric car maker explained the rationale behind its statements about the Model 3.
The Model 3 has since gained perfect 5-Star Safety Ratings from the Euro-NCAP and the ANCAP, with both safety agencies lauding the vehicle for being one of the safest cars on the road. Following the vehicle’s crash tests, Matthew Avery, head of research at Thatcham Research, which conducts the crash tests with the Euro NCAP, noted that “Tesla has done a great job of playing the structural benefits of an electric vehicle to its advantage. The Tesla Model 3 achieved one of the highest Safety Assist scores we have seen to date.” These sentiments were echoed by ANCAP Chief Executive Officer James Goodwin, who noted that it was “great to see electric vehicles continuing to prioritize safety. It is encouraging to see Tesla give equal attention to the active safety systems and technologies on board as well as the safety fundamentals through the structure and restraints.”
H/T to Vladimir Grinshpun.
Investor's Corner
Tesla bear turns bullish for two reasons as stock continues boost
“I think from a trading perspective, it looks very interesting,” Nathan said, citing numerous signs of strength, such as holding its 200-day moving average and holding against its resistance level.
A Tesla bear is changing his tune, turning bullish for two reasons as the company’s stock has continued to get a boost over the past month.
Dan Nathan, a notorious skeptic of Tesla shares, said he is changing his tune, at least in the short term, on the company’s stock because of “technicals and sentiment,” believing the company is on track for a strong Q3, but also an investment story that will slowly veer away from its automotive business.
“I think from a trading perspective, it looks very interesting,” Nathan said, citing numerous signs of strength, such as holding its 200-day moving average and holding against its resistance level.
He also said he believes a rally for the stock could continue as it heads into the end of the quarter, especially as the $7,500 electric vehicle tax credit is coming to an end at the end of the month.
With that being said, he believes the consensus for Q3 deliveries is “probably low,” as he believes Wall Street is likely underestimating what Tesla will bring to the table on October 1 or 2 when it reports numbers for the quarter.
Tesla bear Dan Nathan has flipped his script on Tesla $TSLA shares, citing “technicals and sentiment”
— TESLARATI (@Teslarati) September 12, 2025
Tesla shares are already up over five percent today, with gains exceeding nine percent over the past five trading days, and more than fourteen percent in the past month.
While some analysts are looking at the performance of other Mag 7 stocks, movement on rates from the Federal Reserve, and other broader market factors as reasoning for Tesla’s strong performance, it appears some movement could be related to the company’s recent developments instead.
Over the past week, Tesla has made some strides in its Robotaxi program, including a new license to test the platform in the State of Nevada, which we reported on.
Tesla lands regulatory green light for Robotaxi testing in new state
Additionally, the company is riding the tails of the end of the EV tax credit, as inventory, both new and used, is running extremely low, generally speaking. Many markets do not have any vehicles to purchase as of right now, making delivery by September 30 extremely difficult.
However, there has been some adjustments to the guidelines by the IRS, which can be read here:
Tesla is trading at around $389 at 10:56 a.m. on the East Coast.
Elon Musk
Analyst: Elon Musk’s $1 trillion Tesla pay deal modest against robot market potential
Jonas highlighted Tesla’s longer-term ambitions in robotics as a key factor in his assessment.
Morgan Stanley analyst Adam Jonas, one of Wall Street’s most ardent Tesla (NASDAQ:TSLA) bulls today, has described Elon Musk’s newly proposed $1 trillion performance-based compensation package as a “good deal” for investors.
In a note shared this week, Jonas argued that the package helps align the interests of Musk and Tesla’s minority shareholders, despite its shockingly high headline number.
Future market opportunities
Jonas highlighted Tesla’s longer-term ambitions in robotics as a key factor in his assessment. “Yes, a trillion bucks is a big number, but (it) is rather modest compared to the size of the market opportunity,” Jonas wrote. He added that the humanoid robot market could ultimately surpass the size of today’s global labor market “by a significant multiple.”
“We have entertained scenarios where the humanoid robot market can exceed the size of today’s global labor market… by a significant multiple,” Jonas wrote, as shared on X by Tesla watcher Sawyer Merritt.
The analyst likened the arrival of AI-powered robotics to the transformative effect of electricity, noting that “contemplating future global GDP before AI robots is like contemplating global GDP before electricity.” The Morgan Stanley analyst’s insights align with the idea that as much as 80% of Tesla’s future valuation could be tied to its Optimus humanoid robot program.
Elon Musk’s pay package
Tesla’s board has tied Elon Musk’s proposed compensation package to some of the most ambitious targets in corporate history. The 2025 CEO Performance Award requires the automaker’s valuation to soar from roughly $1.1 trillion today to $8.5 trillion over the next decade, a level that would make Tesla the most valuable company in existence.
The plan also demands a leap in Tesla’s operating profit, from $17 billion in 2024 to $400 billion annually. It also ties the CEO’s compensation to a number of product milestones, including the delivery of 20 million vehicles in total, 10 million active Full Self-Driving subscriptions, 1 million Tesla Bots, and 1 million Robotaxis in operation. Tesla’s board emphasized that Musk’s leadership was fundamental to achieving such ambitious goals, with Chair Robyn Denholm noting the award would align the CEO’s incentives with long-term shareholder value.
Elon Musk
Tesla board reveals reasoning for CEO Elon Musk’s new $1 trillion pay package
“Yes, you read that correctly: in 2018, Elon had to grow Tesla by billions; in 2025, he has to grow Tesla by trillions — to be exact, he must create nearly $7.5 trillion in value for shareholders for him to receive the full award.”
Tesla’s Board of Directors has proposed a new pay package for company CEO Elon Musk that would result in $1 trillion in stock offerings if he is able to meet several lofty performance targets.
Musk, who has not been meaningfully compensated since 2017, completed his last pay package by delivering billions in shareholder value through a variety of performance-based “tranches,” which were met and resulted in the award of billions in stock.
Elon Musk’s new pay plan ties trillionaire status to Tesla’s $8.5 trillion valuation
However, Musk was unable to claim this award due to a ruling by the Delaware Chancery Court, which deemed the payout an “unfathomable sum.”
Now, the company is taking steps to ensure Musk gets paid, as the Board feels that it is crucial to retain its CEO, who has been responsible for much of the company’s success.
This is not a statement to undermine the work of all of Tesla’s terrific employees, but a ship needs to be captained by someone, and Musk has proven he is the right person for the job.
The Board also believes that, based on a statement made by the company in its proxy, various issues will be discussed during the upcoming Shareholder Meeting.
Robyn Denholm and Kathleen Wilson-Thompson recognized Musk’s contributions in a statement, which encouraged shareholders to vote to approve the payout:
“We’re asking you to approve the 2025 CEO Performance Award. In designing the new performance award, we explored numerous alternatives. Ultimately, the new award aims to build upon the success of the 2018 CEO Performance Award framework, which ensure that Elon was only paid for the performance delivered and incentivized to guide Tesla through a period of meteoric growth. The 2025 CEO Performance Award similarly challegnes Elon to again meet a series of even more aspirational goals, including operational milestones focused on reaching Adjusted EBITDA targets (thresholds that are up to 28 times higher than the 2108 CEO Performance Award’s top Adjusted EBITDA milestone) and rolling out new or expanded product offerings (including 1 million Robotaxis in commercial operation and delivery of 1 million AI Bots), all while growing the company’s market capitalization by trillions of dollars.
Yes, you read that correctly: in 2018, Elon had to grow Tesla by billions; in 2025, he has to grow Tesla by trillions — to be exact, he must create nearly $7.5 trillion in value for shareholders for him to receive the full award.
In addition to these unprecedented performance milestones, the 2025 CEO Performance Award also includes innovative structural features, born out of the special committee’s considered analysis and extensive shareholder feedback. These features include supercharged retention (at least seven and a half years and up to 10 years to vest in the full award), structural protections to minimize stock price volatility due to administration of this award and, thereafter, incentives for Elon to participate in the Board’s continued development of a framework for long-term CEO Succession. If Elon achieves all the performance milestones under this principle-based 2025 CEO Performance Award, his leadership will propel Tesla to become the most valuable company in history.”
Musk will have a lot of things to accomplish to receive the 423,743,904 shares, which are divided into 12 tranches.
However, the Board feels he is the right person for the job, and they want him to remain the CEO. This package should ensure that he stays with Tesla, as long as shareholders feel the same way.
Tesla Board Chair discusses what is being done to protect CEO Elon Musk
Tesla bear turns bullish for two reasons as stock continues boost
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