Interpretation ID: aiam1030
Wiggins & Christian
602 First Federal Building
Post Office Box 994
Fort Smith
AR 72901;
Dear Mr. Wiggins: This is in response to your letter of February 27, 1973, concerning th application of the new Federal Odometer Disclosure Requirements to transfers between dealers.; The Federal requirements apply, with certain exceptions, to eac transfer of ownership of a motor vehicle. Some types of vehicles, such as heavy trucks and antique vehicles, are exempt. Passenger cars and lighter vehicles, however, are exempted only in the case of transfers of *new* vehicles from a manufacturer or a distributor to a dealer or from one dealer to another. The transfer of a *used* car or light truck, whether from dealer to dealer, dealer to wholesaler, or dealer to customer, must be accompanied by a disclosure statement.; Yours truly, Richard B. Dyson, Assistant Chief Counsel