Interpretation ID: aiam4233
State of Tennessee
Department of Revenue
Andrew Jackson State Office Building
Nashville
TN 37242;
Dear Mr. McRedmond: I have reviewed your letter of November 14, 1986, and the Tennesse Certificate of Title and Application for Certificate of Title which you forwarded to me. As I advised you previously, the Tennessee Certificate of Title may not be used in lieu of a separate odometer disclosure statement.; Federal regulation, 49 C.F.R. S580.4(e), requires that the transfere shall acknowledge receipt of the disclosure statement by signing it. Therefore, the signature must be on the same document with the disclosure information and not on a separate piece of paper. The National Highway Traffic Safety Administration considers the signature to be essential. In addition to being an acknowledgement of receipt, it prevents the purchaser from later alleging that he was not informed of the mileage. Furthermore, the buyer's signature is important to investigative and prosecutional efforts.; I urge you to notify Tennessee dealers and distributors that thei failure to issue and/or return a separate odometer disclosure statement may subject them to civil and criminal penalties.; Sincerely, Erika Z. Jones, Chief Counsel