Interpretation ID: aiam2763
Rohm and Haas Company
Independence Mall West
Philadelphia
PA 19105;
Dear Ms. Greene: This is in response to your letter of January 27, 1978, requesting tha the National Highway Traffic Safety Administration review the draft of the form with which you propose to satisfy the Federal odometer requirements.; The form you are proposing to use differs from the Federal form in tha the two sets of certifications are combined into an introductory certification with four exceptions. The regulations require the transferor to certify that the odometer reading reflects the actual mileage, reflects the mileage over 99,999 miles, or is not actual. Your form would allow a transferor to execute a disclosure statement without making any of the above certifications. The introductory statement says 'if none of the exception block(s) below is checked, the Seller hereby certifies. . . .' Therefore, by checking the third or fourth box the transferor would be indicating that the exception applies but neither of the introductory statements applies. For this reason we cannot give our approval to use this form as the Federal disclosure form.; Sincerely, John Womack, Assistant Chief Counsel