Interpretation ID: nht90-1.67

TYPE: Interpretation-NHTSA

DATE: March 9, 1990

FROM: Richard L. Martinez -- Santa Fe Insurance Agency.,Inc.

TO: Taylor Vinson -- Attorney-at-Law.,NHTSA

ATTACHMT: Attached to letter dated April 25, 1990 To Richard L. Martinez and From Stephen P. Wood; (A35; Part 592)

TEXT:

Thank you very much for talking with me earlier in the week about Europa's interest in importing the Mercedes-Benz G - Wagon. As I understand from the principal of Europa, they intend to apply for an independent commercial importer's license under the EPA, and also as a registered importer under the Department of Transportation. I wanted to find out if you could provide me with a little more information about the $2,000 liability policy that we spoke about. I've been making some inquiries with property and casualty insurance companies, and they are completely befuddled by the matter; so I've now gone to some of the specialty markets that provide warranty coverages. Since I've only sent out the inquiries today, it will probably be a while before I hear back from them. In the interim, here are some questions I would appreciate your reviewing: 1) Is it required that the term of the policy be for eight years from the date of purchase/sale? 2) The limit is $2,000. Would that apply annually or would it be for the entire eight-year period? The reason for this question is that the companies are wondering whether or not this is a cumulative limit, e.g., $2,000 x eight years = $16,000. 3)You mentioned that the policy was to cover non-compliance or safety defect situations. What are areas specifically to be covered: emissions controls, latent defects, brake problems, warranty situations such as drive train, etc.? 4) Europa is looking into whether or not MBNA would provide a warranty policy as they currently do for their private passenger vehicles. This present warranty covers for a 12/12 plan. If they were to extend this, is it possible that that could be acceptable as an alternative to the $2,000 limit? Some of these questions might appear to be somewhat naive, but since this is fairly new ground for ourselves and Europa, please March 9, 1990 Richard L. Martinez -- Santa Fe Insurance Agency.,Inc.

bear with us. Any further information you can provide us with would be greatly appreciated. I look forward to hearing from you.