Interpretation ID: aiam1111
State of Washington
Department of Motor Vehicles
Olympia
WA 98504;
Dear Mr. Barclift: This is in reply to your letter of March 27, 1973, concerning th acceptability of the State of Washington title application form as a means of conforming to the Federal odometer disclosure requirements in new car transactions.; Although we are not anxious to increase the paper work burden in ne car transactions, without good reason, there have been indications of a variety of misleading practices involving new cars and we drafted the requirements to place new car transactions, with one exception, on the same footing as used car transactions. We would therefore urge that a full statement be given to new car purchasers, or at the least, that a statement containing the balance of the information required by section 580.4 be appended to the application form.; The exception is the transfer between dealers of a new car prior to it first sale to a customer. Your letter indicates that you may have overlooked this exception, which is found in section 580.5(b).; Sincerely, Lawrence R. Schneider, Chief Counsel