Interpretation ID: aiam3745
219 West Bel Air Avenue
Aberdeen
MD 21001;
Dear Mr. Major: This is in response to your letter of August 18, 1983, in which yo assert that the Maryland Certificate of Title does not comply with the Federal Odometer disclosure statement requirements.; Your assertion is incorrect. States are permitted to use their titl documents in lieu of a separate Federal form, provided that the State form contains the odometer disclosure information specified in 49 CFR Part 580. Maryland's Certificate of Title contains this information and, therefore, satisfies the Federal odometer disclosure statement requirements. For your information, I have enclosed a copy of Part 580.; You also requested an interpretation regarding whether the installatio of a replacement engine of unknown mileage will require the transferor to report the mileage on the certificate as being unknown. The answer is no.; Section 408 of the Motor Vehicle Information and Cost Savings Act, 1 U.S.C. S 1968, and its implementing regulations, require the transferor of a motor vehicle to disclose to the transferee the cumulative mileage registered on the odometer or, that the actual mileage is unknown, if the odometer reading is known to be different from the number of miles the *vehicle* has actually traveled.; The Act does not require the separate disclosure of the number of mile traveled by the motor vehicle components, nor is there a mechanism in motor vehicles to measure the distance traveled by each component. Therefore, the installation of a replacement engine will not change the disclosure requirements of the transferor.; Sincerely, Frank Berndt, Chief Counsel