Interpretation ID: aiam3962
Pennsylvania Bureau of Motor Vehicles
Room G-112
Transportation and Safety Building
Harrisburg
PA 17122;
Dear Ms. Walborn: After the promulgation of the Federal odometer disclosure requirements 49 CFR Part 580, the State of Pennsylvania requested from the National Highway Traffic Safety Administration, approval to use the certificate of title in lieu of a separate odometer disclosure statement. The Agency granted that request.; It has come to our attention that some dealers have purchased vehicles altered the odometer reading on the title and subsequently reassigned the title, without signing it and without listing their address. While the Pennsylvania title provides a space for the purchaser's address and signature, the information is apparently furnished only when the buyer applies for title. Due to the practice of permitting a dealer to reassign titles without applying for them in his own name, it has become necessary for us to qualify our initial determination.; Unless the first buyer applies for title in Pennsylvania, a separat odometer disclosure statement, signed by the buyer and containing his address must be issued and a photostat or other facsimile retained by the transferor. This information is required by 49 CFR 580.4, and must be included upon the certificate of title before that document can be used in lieu of a separate statement. 49 CFR 480.4(f)(1) (sic). The Agency finds the buyer's signature to be of utmost importance. The signature serves as an acknowledgement that the purchaser was aware of the mileage. It prevents the buyer from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the odometer. Likewise, the address of an intervening dealer-owner is important, should subsequent investigation or enforcement actions become necessary. You may find it feasible to change the format of Pennsylvania's title to include the purchaser's address and signature on the assignment or reassignment space.; If I can be of further assistance, do not hesitate to contact me or Ms Judith Kaleta of my staff at (202) 426-1834.; Sincerely, Jeffrey R. Miller, Chief Counsel