Interpretation ID: aiam3754
The Good Sam Club
P.O. Box 500
Agoura
CA 91301;
Dear Ms. McBride: As requested in your letter of July 8, 1982, please find a copy of th agency's July 1, 1982 letter to Arthur L. Smith of Tempe, Arizona explaining the application of the Federal odometer laws to devices which tow vehicles without the odometer registering the towed mileage. *Motor Vehicle Information and Cost Savings Act* (15 U.S.C. 1981 *et seq.*) and the *Odometer Disclosure Requirements* (49 CFR Part 580).; As we stated in our letter to Mr. Smith, the agency does not hav sufficient information to determine whether any violation of the law has occurred with respect to these particular devices. However, the agency views devices which cause the odometer not to register mileage when the vehicle is towed as prohibited by the Federal odometer laws.; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel