Interpretation ID: aiam3860
Esq.
Assistant Attorney General
State of Georgia Department of Law
132 State Judicial Building
Atlanta
GA 30334;
Dear Mr. Rosenthal: This is in response to your letter of October 21, 1983 inquiring as t policy of the National Highway Traffic Safety Administration with respect to routine use by dealers of the 'unknown' block on Odometer Disclosure Statements when there is no actual knowledge that the mileage shown on the odometer is not accurate. I apologize for the delay in answering your inquiry.; On several occasions in the past, this office has issued interpretatio letters expressing disapproval of the practice you describe. I have enclosed copies of three such letters, dated November 14, 1978, February 3, 1978, and October 28, 1976, for your information. It is our position that a statement by the transferor on the odometer disclosure statement that the mileage is unknown when he has no actual knowledge that the mileage is inaccurate significantly inhibits enforcement of the Federal odometer law (Title IV of the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. SS1981-19991 (sic)) by making it more difficult to trace violations through the chain of title.; I hope you find this information helpful. Sincerely, David W. Allen, Assistant Chief Counsel