Interpretation ID: aiam1301
Esq.
Moore
Weaver
Moore & Bradberry
13185 Warwick Boulevard
P.O. Box 2228
Newport News
VA 23602;
Dear Mr. Weaver: Your letter to Secretary Brinegar of October 8, 1973, has been referre to me for reply.; A copy of Part 580, *Odometer Disclosure Requirements*, is enclosed This disclosure regulation became effective March 1, 1973, and we assume that the August 1972 date in your letter actually refers to an August 1973 sale which would be subject to the regulation.; Title 15 U.S.C. S 1939 provides a remedy for a violation of the Ac made with intent to defraud. A discrepancy between the odometer reading and the disclosure statement could be the result of error, or misunderstanding of the requirement, and by itself, would not establish an intent to defraud.; We are unfamiliar with the facts in the case you mentioned, and th above statement should not be construed as an opinion or evaluation of the merits of that case.; Sincerely, Lawrence R. Schneider, Chief Counsel