SDCL § 32-3-35: Manufacturer's statement or certificate of origin pending issuance of certificate of title--Priority of liens.

A manufacturer's statement of origin or manufacturer's certificate of origin shall be deemed to be in possession of the lien holder while being transmitted to the secretary and until issuance of a certificate of title by the secretary showing the lien. All contracts, liens, mortgages, and encumbrances, noted on a certificate of title, shall take priority according to the order of time in which the liens were noted.