Interpretation ID: aiam3312
Commissioner
Indiana Bureau of Motor Vehicles
State Office Building
Indianapolis
IN 46204;
Dear Mr. Packard: This is in response to your letter of May 28, 1980, in which yo requested approval to use Indiana's Certificate of Title as a substitute for the Federal Odometer disclosure form required by 49 CFR Part 580.; Because the Federal odometer requirements that became effective as o January 1, 1978, contain a good deal of wish to include odometer information on their titles to use a shortened form that was adopted by the American Association of Motor Vehicle Administrators (AAMVA). We consider the AAMVA form to include the minimum amount of information necessary for an adequate disclosure. In addition to the information included on the Certificate of Title which you submitted to our office, the following information is also required:; >>>(1) a reference to State or Federal law, (2) a statement that the odometer reading reflects the amount o mileage over 99,999 miles,; (3) a statement that the odometer mileage is not actual, (4) the signature of the buyer.<<< Without these four items the title cannot be used in lieu of a separat Federal form. If this information is included, the National Highway Traffic Safety Administration will approve the title for use in lieu of the Federal form.; Sincerely, Frank Berndt, Chief Counsel