Interpretation ID: aiam4138
B.B. Foreign Car Sales
2983 El Camino Real
Santa Clara
CA 95051;
Dear Ms. Smith: Thank you for your recent telephone call requesting information on th Federal odometer law. Enclosed is a copy of Title IV of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1981 *et seq.*), which is the pertinent statute, as well as regulations prescribing odometer disclosure requirements (49 CFR Part 580), and a fact sheet that we have prepared on this subject.; Section 580.4 of the regulations prescribes the contents of th disclosure statement which must be furnished by the buyer to the seller at the time ownership of a motor vehicle is transferred. This includes the odometer reading at the time of transfer, the date of transfer, the name, address, and signature of both the buyer and seller, and a statement indicating either that the odometer reflects actual miles driven or that the true mileage is unknown.; You asked whether it is necessary for odometer disclosure statements t be furnished when ownership of a new vehicle is transferred. Under section 580.5(b) of the regulations, the odometer reading of a new vehicle need not be disclosed prior to its first transfer for any purposes other than resale. This exemption does not apply when ownership of the vehicle is transferred to the first retail customer. It is consequently necessary for your dealership to furnish odometer disclosure statements in transactions of this nature. As provided in section 580.7 of the regulations, it must furthermore retain a copy of these statements for a period of four years at its principal place of business in a manner that permits systematic retrieval.; I hope this information has been helpful. If we can be of any furthe assistance, please feel free to contact us again.; Sincerely, David W. Allen, Assistant Chief Counsel