Interpretation ID: aiam1076
State of New Jersey
Division of Motor Vehicles
25 South Montgomery Street
Trenton
NJ 08666;
Dear Mr. Marini: This is in response to your letter of March 5, 1973, concerning th recently issued Federal odometer disclosure requirements.; Although we have not had the opportunity to review the revised Ne Jersey certificate of ownership, it appears that New Jersey is proceeding along lines that could make the certificate usable for purposes of compliance with our regulations. We are concerned, however, about the possibility of variance between State and Federal procedures.; The Federal regulation requires the transferor to state the mileage o the odometer at the time of transfer. In addition, if he knows the odometer reading to be wrong, he must so state by indicating that the actual mileage is unknown. Provision for a disclosure of odometer error is essential to the Federal regulation, and it is not clear to us that the New Jersey certificate provides for such a disclosure.; With respect to the older vehicles - those not subject to a revise certificate of ownership - the form attached to your letter will satisfy the Federal requirements. A disclosure statement of this type is required by our regulation to be made upon each transfer of a vehicle. I would hope that all dealers in New Jersey are receiving, and giving, such statements in each motor vehicle transaction.; Sincerely, Lawrence R. Schneider, Chief Counsel