Interpretation ID: aiam2836
Motor Vehicle Administration
Maryland Department of Transportation
6601 Ritchie Highway
N.E.
Glen Burnie
MD 21062;
Dear Mr. Pfaff: Thank you for your letter of June 16, 1978, requesting our opinion o whether the Maryland Certificate of Title meets the Federal requirements for the odometer disclosure form as set forth in 49 CFR Part 580.; The proposed Certificate of Title which you enclosed with your lette differs from the Federal odometer disclosure form in the following ways:; (1) The Maryland Certificate of Title shortens the reference to th Federal law,; (2) the set of certifications relating to the distance that the vehicl has travelled are shortened by adopting language similar to that recommended by the American Association of Motor Vehicle Administrators,; (3) the certifications relating to alteration of the odometer ar deleted, and; (4) although the transferee is required to sign the statement, th signature does not specifically acknowledge receipt of a copy of the statement, as is required by the Federal law.; The National Highway Traffic Safety Administration (NHTSA) has reviewe Maryland's proposed Certificate of Title and has determined that it will further the goal of the Federal odometer law, despite its differences from the Federal form. Therefore, pursuant to 49 CFR S 580.4(f)(2), I hereby grant your request to use Maryland's Certificate of Title as a substitute for the Federal odometer disclosure form.; Sincerely, John Womack, Assistant Chief Counsel