Interpretation ID: aiam0381
President
Chase Manhattan Capital Corporation
1 Chase Manhattan Plaza
New York
NY 10005;
Dear Mr. Allen: This is in reply to your letter of June 21, 1971 concerning the Tir Identification and Record Keeping regulation (49 CFR Part 574). We are concerned with the points you raise in your letter regarding the confidentiality of tire dealers customer's lists and the extra burden the regulation causes dealers who handle more than one brand of tires.; However, under the National Traffic and Motor Vehicle Safety Act we d not feel we have authority to require the tire manufacturer to choose someone as his designee. Section 113(f) of the Act makes the tire manufacturer responsible for maintaining the records of first purchasers.; As you probably know, any use of the customer's list by the tir manufacturer is expressly prohibited by the regulation. Any violation of this prohibition will be enforced.; I have enclosed for your information a copy of a notice published i the *Federal Register* May 28, 1971 which is relevant to the points you raise.; Thank you for your comments and interest in auto safety. Sincerely, Lawrence R. Schneider, Acting Chief Counsel