Interpretation ID: aiam4134
1830 North Ridge Street
Coralville
IA 52241;
Dear Mr. Quick: Thank you for your recent telephone call in which you asked whether i would be legally permissible for an odometer which is being installed in your automobile to replace one that was registering high mileage to be set at the mileage that the automobile was actually driven. There is regrettably no means for this to be done under the Federal odometer law. Section 407 of the Motor Vehicle Information and Cost Savings Act, as found in 15 U.S.C. 1987, permits the 'replacement of an odometer, provided the mileage indicated thereon remains the same as before the . . . replacement.' No adjustments are permitted to compensate for any excess mileage that may have registered on the odometer being replaced. Although some may regard this as being unduly stringent, the creation of such a loophole could invite fraudulent abuse and seriously undermine the effectiveness of our odometer enforcement program.; Enclosed for your information is a copy of the statute and regulation that establish odometer requirements, together with a fact sheet that we have prepared on the subject.; If we can be of any further assistance, please feel free to contact u again.; Sincerely, David W. Allen, Assistant Chief Counsel