Interpretation ID: aiam2933
Gladiator Southeast
1250 8th Street
Jacksonville
FL 32205;
Dear Ms. Malinovsky: This is in response to your letter of October 30, 1978, requestin information on the Federal Odometer Mileage Statement. Section 580.5(b) of Title 49 Code of Federal Regulations provides; >>>A transferor of a new vehicle prior to its first transfer fo purposes other than resale need not disclose the vehicle's odometer mileage.<<<; Manufacturers of vehicles fall within this section and are exempt fro the disclosure requirements because they sell vehicles to dealers who intend only to resell the vehicles. Since Gladiator, Inc. purchased the vans new with the intent to resell them and since the vans are being sold to dealers only who also intend only to resell them, Gladiator is likewise exempt from the disclosure requirements. The dealerships, however, will be selling the vans to customers who will use them for some purpose other than resale. Consequently, the dealerships are required to issue disclosure statements each time they sell a van.; Sincerely, John Womack, Assistant Chief Counsel