Interpretation ID: aiam1707
General Manager
The Fairmount Press
P.O. Box 3
Bronx
NY 10453;
Dear Mr. Salzman: This is in response to your letter of November 18, 1974, enclosin amended copies of your MVF disclosure form for our review.; The disclosure forms contained in your letter fail to conform to Par 580, *Odometer disclosure requirements*, in two of the aspects described in our letter to you of September 27, 1974. 49 CFR Part 580.4(a) specifies that the transferor of a motor vehicle must furnish his transferee with a written odometer disclosure statement 'before issuing any transfer of ownership document.' Subparagraph (1) of that subsection requires that the disclosure statement include the 'odometer reading at the time of transfer.' The mileage disclosure section of your form is phrased so as to suggest that the odometer mileage was disclosed *after* the completion of transfer. This is contrary to the regulation's provisions and should be corrected to clearly express that the mileage is being disclosed at the time of the vehicle's transfer. Insertion of the word 'is' instead of 'was ' just prior to the odometer mileage disclosure will bring your form into conformity with the regulation.; The requirement in section 580.4(3) of the regulation provides that th transferor make an odometer disclosure by executing 'the disclosure form specified'. While we have not gone so far as to interpret this to require a verbatim copy of our format, we do insist that any variations do not change the significance of the specified formula. In our form, the use of the words 'I, *(transferor's name) state that . . .' is intended to make it clear that the factual representations of the form are those of the transferor. Any formula that fails to accomplish this will not be considered in conformity with the regulation.; I have enclosed a corrected copy of your disclosure form in order t make clear the changes necessary for compliance.; Yours truly, Richard B. Dyson, Acting Chief Counsel