Interpretation ID: aiam1130
Virginia-Carolina Auto Auction
Inc.
Post Office Box 2244
Danville
VA 24541;
Dear Ms. Dowdy: This is in response to your letter of May 11, 1973, in which you ask i the federal odometer disclosure statement may be incorporated in the title of an automobile transfered (sic) at auction.; You may include the disclosure statement on the title or other documen which accompanies the transfer so long as it is executed prior to the transfer. In addition to recording the mileage on the title, the statement would have to contain (1) the date of the transfer, (2) transferor's name and current address, (3) vehicle identification or serial number, make, model, year, body-type, last plate number, (4) a statement that actual mileage differs from recorded mileage if such is the case and the transferor knows it, and (5) reference to the Motor Vehicle Information and Cost Savings Act with the statement that incorrect information may result in civil liability under it.; An example of an adequate statement and format is enclosed for you information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel