Interpretation ID: aiam2050
Assistant Attorney General for Consumer Protection
Room 419
Supreme Court Building
Nashville
TN 37219;
Dear Mr. Koch: As you requested in your August 29, 1975, telephone conversation wit Karen Kreshover of this office, I am forwarding to you an interpretation of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, as it applies to new car dealers.; Section 580.5(b) states that an odometer disclosure form need not b executed by transferors of new vehicles before their first transfer for purposes other than resale. This means that a distributor of new vehicles is not required to provide a dealer with odometer disclosure statements for vehicles he transfers to him. A new vehicle dealer, however, must complete disclosure statements for all vehicles he transfers to person who are taking possession for purposes other than reselling the vehicles. In other words, even a new vehicle which has not been previously sold to a consumer must have its odometer mileage certified in compliance with the odometer disclosure requirements when it is transferred.; Sincerely, Frank Berndt, Acting Chief Counsel