Interpretation ID: aiam1119
General Manager
The Fairmount Press
1993 Jerome Avenue
Bronx
NY 10453;
Dear Mr. Salzman: This is in response to your request for a review of Fairmount Pres forms MFV, ABW, and WH for their conformity with the odometer disclosure requirements of the Motor Vehicle Information and Cost Savings Act.; Form MFV conforms to the requirements, although it appears from th wording of the disclosure that there may be a misunderstanding as to when the disclosure must be given. Your form contains the statement that 'The mileage appearing on the odometer of the motor vehicle described above *at time of transfer* to * was* as follows:' The intent of the regulation is to make disclosure before the transfer, and the MFV form should therefore be executed before transfer, notwithstanding the quoted language.; Form ABW incorporates the disclosure in the bill of sale, as permitte by the regulations. However, the statement is deficient because there is no provision for (1) last plate number, (2) body style, (3) model, and (4) a check-off provision in the situation where the transferor knows the indicated mileage is incorrect.; Form WH is similarly deficient in that there is no provision for (1 body style, (2) last plate number, and (3) a check-off provision in the situation where the transferor knows the indicated mileage is incorrect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel