Interpretation ID: aiam3574
Esq.
Legal Aid of Western Missouri
1103 Grand Avenue
Kansas City
MO 64106;
Dear Mr. Smith: This is in response to your letter of June 10, 1982, concerning whethe the odometer disclosure statement on the Missouri certificate of title has been approved for use in lieu of the Federal odometer disclosure statement.; The Motor Vehicle Information and Cost Savings Act ('Act') (15 U.S.C S1981 *et seq*.) prohibits the disconnection, resetting or alteration of a vehicle odometer with the intent to change the number of miles. The Act also requires that a written disclosure of the mileage registered on the odometer be provided by the seller to the buyer at the time ownership of a vehicle is transferred. 15 U.S.C. S1988. Each dealer or distributor of a motor vehicle is required by law to retain for four years a copy of each odometer statement he issues and receives. Odometer Disclosure Requirements ('regulations') (49 CFR Part 580).; The Odometer Disclosure Requirements provide that the transferor of 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 approval process the agenc 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 document can be considered to be approved for use as a ful 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.; Missouri has not submitted its certificate of title to the agency fo approval as a substitute for the Federal odometer disclosure statement so, therefore, the agency does not know whether Missouri's certificate of title can be substituted for the Federal odometer disclosure statement.; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel