delivery of the required documents and fees to the clerk constituted filing. Id. at 1005 (citing Commonwealth v. O'Bryan, Utley & Company, 153 Ky. 406, 155 S.W. 1126, 1128 (1913)) ("In modern times it is usually held that a paper is filed on behalf of the party who is required to file it when he has presented it at the proper office and left it with the person in charge thereof and paid the fees for filing, if any are required.”). In contrast to the law in Kentucky at the time of Fields Motor, Kentucky law today is clear that actual notation on the title is required before a lien is truly perfected and mere filing or tender is insufficient to constitute notation. See supra Footnote 4; see also Vanderbilt Mortgage & Fin., Inc. v. Griggs (In re Griggs), 965 F.2d 54, 56 (6th Cir.1992) (<HOLDING>); Hiers v. Bank One, West Virginia, Williamson,
holding that the sensible and popular understanding of what a motor vehicle accident entails necessarily involves the motor vehicle being operated as a motor vehicle  recognizing that in 1982 kentucky converted to a new title system for motor vehicles under which the secured creditor must perfect its security interest by noting the lien on the certificate of title to the motor vehicle recognizing kentucky as a state where actual notation of the secured partys lien on the certificate of title is a prerequisite for perfection of a security interest in a motor vehicle holding that a summons directed to the commissioner of motor vehicles was defective process as against a nonresident defendant in an action arising out of operation of a motor vehicle in this state holding that normal presumption of ownership in favor of holder of motor vehicle certificate of title may be rebutted despite language of minnstat  168a10 subd 5 providing that the transfer of a motor vehicle is not effective until titling requirements are complied with