Interpretation ID: aiam3323
U.S.A.A.
P.O. Box 33400
San Antonio
TX 78233;
Dear Mr. Middleton: This is in response to your telephone call of August 6, 1980, to Kath DeMeter of my staff concerning odometer information on state certificates of title.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted titles to the agency askin for approval but had inacceptable statements. Each was informed that if they supplied certain additional information their titles would be in conformance. We do not know whether that information was included on the titles:; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah Wisconsin<<<; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1 notice, a copy of which is enclosed.; If you have any further questions, please do not hesitate to write. Sincerely, John Womack, Assistant Chief Counsel