Interpretation ID: aiam1043
Manager
Transportation Administration
Kraft Foods
500 Peshtigo Court
Chicago
IL 60690;
Dear Mr. Bourne: This is in response to your letter of February 26, 1973, concerning th Federal Odometer Disclosure Requirements.; With respect to your first question, we confirm your understanding tha a commercial firm trading a vehicle having a gross weight of 16,000 pounds or less is required to give the dealer a disclosure statement.; Your second question concerns the intent of the phrase 'creating security interest,' as used in the definitions of transferee and transferor in section 580.3. The quoted phrase was used to exclude parties to transactions in which liens and similar interests in vehicles are created, but in which the ownership of the vehicle does not change. For example, a bank that lends money for the purchase of a vehicle and that secures its loan by a lien on the vehicle is not a transferee. A dealer who sells a vehicle conveys his ownership and is therefore a transferor, even though he may *also* create a security interest by placing a lien on the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel