Interpretation ID: aiam4224
Motor Vehicle Division
500 Deaderick Street
Nashville
TN 37242;
Dear Mr. McRedmond: The National Highway Traffic Safety Administration has been informe that you have been advising dealers that the Tennessee Certificate of Title may be used in lieu of a separate odometer disclosure statement. We have reviewed the title and have determined that it fails to meet the requirements of the Federal odometer disclosure regulation, 49 C.F.R. Part 580.; The Tennessee title cannot be used in lieu of a separate odomete disclosure statement. Although the National Highway Traffic Safety Administration allows the use of the abbreviated disclosure statements as they appear on the title, the title fails to meet the regulatory requirements because it does not include a space for the buyer's signature. This Agency considers the signature to be essential. It is an acknowledgment that the purchaser is aware of the mileage and prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Furthermore, the buyer's signature is important to investigative and prosecutorial efforts.; Dealers who do not issue and/or retain a copy of a separate odomete disclosure statement may be liable for civil and criminal penalties. If you have any questions do not hesitate to call Judith Kaleta of my staff at (202) 366-1834.; Sincerely, Erika Z. Jones, Chief Counsel