Interpretation ID: aiam3612
Engineer-Director
State Department of Highways and Public Transportation
Motor Vehicle Division
Austin
TX 78779;
Dear Mr. Goode: This is in response to your letter of September 20, 1983, requestin approval for use of the Texas Certificate of Title and disclosure documents in lieu of the Federal odometer disclosure form which is required by 49 CFR Part 580.; The proposed Texas documents do not conform with the regulation' requirements. To conform, the odometer disclosure statements must include the name and address of both the transferee and the transferor, Section 24(a) of the Texas Certificate of Title Act does require their inclusion. It appears, however, that the disclosure statements do not provide a space for the transferor's (seller's) address. Additionally, a space must be provided on the statements for the transferee's (purchaser's) signature. The Agency considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. If these items are added, the Texas forms will satisfy the Federal odometer disclosure statement requirements, and may be used in lieu of a separate Federal form.; Sincerely, Frank Berndt, Chief Counsel