Interpretation ID: aiam4213
Chief
Title Division
Mississippi State Tax Commission
P.O. Box 960
Jackson
MS 39205-0960;
Dear Mr. Eastland: This is in response to your letter of August 14, 1986, concernin Mississippi House Bill 64 and Federal odometer disclosure requirements.; I have reviewed House Bill 64 and the reverse side of the ne Mississippi certificate of title. The disclosure statements as set forth in lines 155-164 of the bill and on the reverse side of the title conform to the Federal odometer disclosure requirements, 49 C.F.R. S 580.4. However, even assuming the front of the title includes the vehicle's year, make, model and body type and the vehicle identification number, the title fails to include a space for the buyer's signature. The National Highway Traffic Safety Administration considers the signature to be essential because it is an acknowledgement that the purchaser is aware of the mileage. Furthermore, the signature prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title.; Because the title does not contain all the information required b Federal regulation, transferors of motor vehicles in Mississippi must continue to issue a separate odometer disclosure statement. In addition, dealers and distributors must retain, for four years, each odometer statement they receive and a copy of each odometer statement they issue.; I hope this information will help you in your efforts to assist dealer in complying with the Federal regulations. If I could be of further assistance, do not hesitate to contact me.; Sincerely, Erika Z. Jones, Chief Counsel