Interpretation ID: aiam3861
Mr. Jerome Ramsey
Legal Services of Eastern Missouri
Inc.
P.O. Box 4999A
Field Station
625 N. Euclid Avenue
St. Louis
MI (sic) 63108;
Dear Mr. Russo and Mr. Ramsey: This is in response to your letter of August 10, 1984, concernin Missouri's odometer disclosure requirements.; The Missouri disclosure form fails to meet federal disclosur requirements. If Missouri wants to use its Certificate of Title in lieu of the separate Federal form, it must refer to the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. S 1981 *et seq*., state the date of the transfer and provide a space for the purchaser's signature. The National Highway Traffic Safety Administration (NHTSA) considers this signature to be essential. It is an acknowledgment that the purchaser was aware of the mileage and prevents the purchaser from later alleging the contrary.; In addition, the Missouri title certificate fails to meet th requirements of 49 C.F.R. S 580.4(c). While it does provide a space for the odometer mileage, it fails to state that the transferor certifies 'that to the best of his knowledge the odometer reading reflects the actual miles or kilometers the vehicle has been driven.' Furthermore, the form must provide alternate statements that the odometer reading reflects the mileage in excess of 99,999 miles or kilometers or that the mileage is not actual and should not be relied upon.; Please be advised that, to date, Missouri has not requested approva from NHTSA for use of its Certificate of Title as a substitute for the Federal form. If you have any additional questions, please do not hesitate to contact Judy Kaleta of my staff at (202) 426-2992.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law