Interpretation ID: aiam3514
Jr.
Esq.
General Motors Corporation
General Motors Building
3044 West Grand Boulevard
Detroit
MI 48207;
Dear Mr. Brusstar: This is in response to your letter of December 16, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the *Federal Register* notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Massachusetts, Michigan, Minnesota, Ohio, Pennsylvania Hawaii, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved, certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Delaware, South Dakota, South Carolina, Indiana Virginia, Washington, Utah, Wisconsin, New Mexico<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel