Interpretation ID: aiam1010
Southwest Auto Auction
Inc.
2400 South Central Avenue
Phoenix
AZ 85040;
Dear Mr. Klein: This is in reply to your letter of February 8, 1973, concerning th Federal Odometer Disclosure Requirements.; Our response to your three questions is as follows: (1) When a title is transferred several times from dealer to dealer each transferor must complete a disclosure form, not just the registered owner.; (2) Where several sales of a vehicle occur before March 1, 1973, and final sale of the same vehicle occurs after that date, only the final sale must have a disclosure form.; (3) If a transferor is not the original owner and does not know tha the indicated mileage is correct, yet does not *know* that the mileage is *incorrect*, he should state the indicated mileage reading without indicating that the mileage is unknown.; Yours truly, Richard B. Dyson, Assistant Chief Counsel