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Interpretation ID: aiam3924

B. Craig Killough, Esq., 14 North Adgers Wharf, Charleston, SC 29401; B. Craig Killough
Esq.
14 North Adgers Wharf
Charleston
SC 29401;

Dear Mr. Killough: This is in response to your letter dated March 5, 1985 inquiring as t whether South Carolina has obtained approval under 49 CFR S580.4(f)(1) to eliminate the odometer disclosure requirements of 49 CFR S580.4(d).; Some background information may be helpful. Title IV of the Moto Vehicle Information and Cost Savings Act requires vehicle sellers to make certain odometer disclosures, as specified in our regulations (49 CFR S580.4). The general rule is that all information specified in S580.4(a)-(e) must be included on the disclosure form. However, S580.4(f)(1) provides that, if the disclosure is made on the certificate of title, the information specified in S580.4(d) need not be included. If the state wishes to make other variations in the information disclosed on the title, it must obtain approval from this agency to do so.; This agency has not granted approval to South Carolina for use of an alternative odometer disclosure procedures. Nor, to my knowledge, has South Carolina fully incorporated the information required by 49 CFR S580.4(f)(1) into its certificate of title. Please note, however, that if in the future the state does incorporate into its title the appropriate language contained in the regulation, it need not obtain the approval of this agency in order to use that title in lieu of a separate form.; Sincerely, Jeffrey R. Miller, Chief Counsel