Interpretation ID: aiam1049
Mapother and Morgan
521 West Market Street
Louisville
KY 40202;
Dear Mr. Morgan: This is in response to your question concerning the status o repossessing banks and finance companies as transferors under the odometer disclosure requirements of the Motor Vehicle Information and Cost Savings Act.; Banks and finance companies are obliged to make a disclosure upo resale of a repossessed vehicle. It is advisable to provide a disclosure form to be filled out by the defaulting transferor upon repossession. Should the defaulting transferor refuse to complete the form and the odometer is later found to be in error he may be subject to civil action under the Act.; In any case, if the bank or finance company does not know that th mileage is wrong, they should not state that the mileage is in error. If the repossessor wishes to add a statement that the vehicle has been repossessed or otherwise outside his control, he may do so.; Yours truly, Richard B. Dyson, Assistant Chief Counsel